I-3, r. 1 - Regulation respecting the Taxation Act

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1089R9. Despite section 1089R8, where the merchandise sold is shipped to another country where the individual has no establishment and the merchandise was entirely produced or manufactured by the individual in one jurisdiction in Canada, the gross revenue derived from the sale is attributable to the establishment situated in that jurisdiction.
However, if the merchandise sold was produced or manufactured by the individual partly in Québec and partly in another jurisdiction, the gross revenue derived from the sale that is attributable to the establishment situated in Quebec is equal to that proportion of the gross revenue that the salaries and wages paid in the year to employees of that establishment is of the aggregate of the salaries and wages paid in the year to employees of all the establishments in Canada where the merchandise sold was produced or manufactured.
The same rules apply where the establishment of the buyer is situated in a jurisdiction outside Canada in which the individual has no establishment and the buyer instructs that the merchandise be shipped to another person.
s. 1089R9; O.C. 1981-80, s. 1089R9; R.R.Q., 1981, c. I-3, r. 1, s. 1089R9; O.C. 134-2009, s. 1.