Subsection 19.1(1) - Limitation re advertising expense on broadcasting undertaking
Administrative Policy
23 November 1999 TI 990781
A fee paid "for the purpose of preventing or limiting others from advertising during certain time slots or controlling who can advertise in those time slots" would not represent an expense incurred for an advertisement and, accordingly, would not be limited by s. 19.1.
Subsection 19.1(2) - Exception
Administrative Policy
18 July 1991 Memorandum (Tax Window, No. 6, p. 13, ΒΆ1360)
Discussion of factual criteria respecting whether a particular advertisement is directed primarily to a market in Canada.
Where an advertisement directed to a foreign market is paid for by a Canadian corporation for the benefit of a related foreign corporation, s. 19.1 would not apply but the advertising expense may be disallowed on the basis that it is not related to the business of the Canadian corporation.