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

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771R24.1. For the purposes of section 771R22, where an insurance corporation has no establishment in a taxation year in a particular country other than Canada and offers insurance on property situated in the particular country or has an insurance contract, other than on property, with a person resident in the particular country, each net premium for that year in respect of the insurance is deemed, as the case may be, to be a net premium in respect of insurance on property situated in the province or country other than Canada in which the establishment of the corporation to which the net premium is reasonably attributable is situated, or a net premium in respect of insurance, other than on property, from a contract with a person resident in the province or country other than Canada in which such establishment is situated.
O.C. 1176-2010, s. 32.