[ compiled answer ]
law as at 14 Aug 2026 · settled
Does soliciting orders in Canada through an agent create a Canadian tax presence?
The compiled answer
Yes — ITA s.253(b) DEEMS a non-resident to be carrying on business in Canada where it solicits orders or offers anything for sale there through an agent or servant, whether the contract is completed inside or outside Canada, and whether the agent is independent or not. Solicitation-level conduct suffices — no authority-to-conclude gloss survives the drafting. A treaty may relieve the tax, but the filing machinery (T2 return; Reg 105 withholding) still bites.
Pinpoint
ITA s.253(b) (Canada)
String-verified quote
“solicits orders or offers anything for sale in Canada through an agent or servant, whether the contract or transaction is to be completed inside or outside Canada”
source: provision:CA.ITA.253B — verified at load; a quote that stops matching its source is a compile error
Computed by a deterministic engine over compiled law — no generative model in the evaluation path. JSON twin: /t/canada_s253b_solicitation.json · Ask with YOUR facts: GET /compute?lookup=… · MCP: POST https://lrlabs.ai/mcp (lookup_compiled_rule)