Provincial income allocation newsletters

A taxpayer who carries on business in more than one province or territory has to determine the income tax payable in each province or territory. Provincial income allocation refers to the formula used to determine the amount of taxable income that must be allocated to each province or territory.

Part IV of the Income Tax Regulations provides the rules for provincial income allocation. However, there may be occasions when the legislation does not address a particular issue. The CRA will develop administrative positions and issue technical opinions with respect to the issues that could potentially apply to a wide variety of situations, in order to ensure the proper allocation of revenues among the provinces and territories and avoid situations of double taxation of the taxpayer.

Legislative changes that affect provincial income allocation, such as amendments to Part IV of the federal Income Tax Regulations, may be explained in a newsletter.

The Provincial Income Allocation Newsletters are publications outlining the CRA's administrative positions and technical opinions on issues specific to provincial income allocation.

• No. 1, Gross Revenue – Exclusion of Interest
• No. 2, Permanent Establishment – Substantial Machinery or Equipment
• No. 3, Gross Revenue – Leasing Revenue
• No. 4, Salaries and Wages – Inclusion of Taxable Benefits