{"url":"https://lrlabs.ai/t/usca_v9_services_pe","engine":"deterministic","llm_in_path":false,"id":"usca_v9_services_pe","question":"When does Article V(9) create a services PE between the US and Canada?","answer":"Two limbs, both needing 183 DAYS OR MORE (not \"more than 183\") in any twelve-month period: (a) an individual present 183+ days AND more than 50% of the enterprise's gross active business revenues derived from services performed there by that individual — the revenue conjunct is mandatory; or (b) services provided 183+ days on the same or connected project for residents of, or PEs in, the other State. Duration alone never suffices under limb (a).","pinpoint":"Article V(9), Canada–US Convention (Fifth Protocol)","confidence":"settled","as_at":"10 Jul 2026","treaty":"USA–Canada","value":183,"quote":"an aggregate of 183 days or more in any twelve-month period with respect to the same or connected project","quote_string_verified":true,"quote_source":"rule:PE.SERVICE.V9B.USCA"}