Non-resident Canadian income is not subject to Income tax

[taxquestions]

Scenario:

S-Corp with Canadian sourced income. S-Corp has products stored in a third-party warehouse in Canada. The S-Corp sells these products to customers in Canada. The third party warehouse ships the products to these Canadian customers for the S-Corp.

I consulted a CPA if this Canadian income would be subject to Canadian income tax. His response:

"You will not be liable for Canadian income tax on the sales made to Canadian customers so long as you do not maintain a PE in Canada. A PE excludes a warehouse for the distribution of goods. However, you will still have to charge GST/HST if your total sales to Canadian customers is $30,000 or more. 25% withholding tax is NA."

Id like a second opinion. Is this statement correct correct?

[taxquestions]

taxquestions wrote:
> Scenario:
>
> S-Corp with Canadian sourced income. S-Corp has products stored in a
> third-party warehouse in Canada. The S-Corp sells these products to
> customers in Canada. The third party warehouse ships the products to these
> Canadian customers for the S-Corp.
>
> I consulted a CPA if this Canadian income would be subject to Canadian
> income tax. His response:
>
> "You will not be liable for Canadian income tax on the sales made to
> Canadian customers so long as you do not maintain a PE in Canada. A PE
> excludes a warehouse for the distribution of goods. However, you will still
> have to charge GST/HST if your total sales to Canadian customers is $30,000
> or more. 25% withholding tax is NA."
>
> Id like a second opinion. Is this statement correct correct?