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Investor Presentaiton

CORPORATE LAW BY ALAIN RANGER BRAZIL - CANADA COMPARATIVE LAW controlled private corporations is 26.5% for general active business income. There are separate rates for general active business income, manufacturing and processing income, investment income and for Canadian-controlled private corporations. A non- resident corporation pays tax on income earned in Canada, subject to certain tax treaty concessions. An abatement is allowed against federal tax in an amount equal to 10% of the corporation's taxable income earned in the Canadian provinces. This abatement is intended to compensate partially for the provincial tax burden. Provincial taxes vary from 11% to 16% (again for general active business income), and generally a corporation is liable to tax in a province only if it has a permanent establishment in that province. Where a corporation has business income attributable to permanent establishments in more than one province, such income is allocated among those permanent establishments and is subject to tax in those provinces in which the permanent establishments are located. In 2016, the combined standard federal-provincial corporate income tax rates on taxable income ranges from 26% to 31% on general active business income for non-CCPCs. The following tables present a snapshot of the applicable tax rates for 2016: Combined Federal and Provincial Income Tax Rates for Income Earned by a Canadian-Controlled Private Corporation (CCPC) Jurisdiction Québec Ontario Alberta British Columbia Small Business Income up to $500,000 General Active Business Income Investment Income 18,5% 26,9% 50,6% 15% 26,5% 50,2% 13,5% 27% 50,7% 13 % 26% 49,7% Combined Federal and Provincial Income Tax Rates for Income Earned by a Corporation other than a CCPC Jurisdiction Québec Ontario Alberta British Columbia General Active Business Income (B) Determination of Residence Investment Income 26,9% 26,9% 26,5% 26,5% 27% 27% 26% 26% A corporation incorporated in Canada after April 26, 1965 is deemed to be resident in Canada. A non-resident corporation may be considered to be resident in Canada if its central management and control is in Canada. 17
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