Hi Madan,

A quick question which I suspect I already know the answer to but thought it worth asking.

I worked under contract as a consultant (in Canada) for 6 years on a monthly retainer/salary paid by a Kuwait based and 100% Kuwaiti owned company – they were my sole client. All of my work was in regards to a Kuwait based project and, although I undertook the work in Canada at my home, all of the work product flowed back to Kuwait for use in Kuwait. I’ve reported 100% of my income in each of the 6 years to CRA but wonder now, based on the wording in the Canada-Kuwait tax treat around “where work is exercised”, if some or all of that income could be construed as taking place in Kuwait and so subject to a different or lessor tax liability in Canada. I suspect not but just wanted to ask…