These bills generally follow the OECD model and our own policy, which is patterned after the OECD model. There are a few things that are different. One of them, for example, is that the taxation of non-resident business in treaties requires a permanent establishment--that is, a substantial presence from a business in a country. In some cases, other countries will insist that the provision of services, without a permanent establishment, is sufficient presence to warrant taxation. And actually in three of these treaties we do have this provision that basically if someone comes to Canada for more than six months providing services, or goes to the other country for more than six months, then they would be taxable in that country.
On October 4th, 2010. See this statement in context.