![]() Pursuant to paragraph 153(1)(g) of the Act and Regulation 105, a withholding of 15% is required from the payment of fees, commissions, or other amounts paid or allocated to a non-resident person in respect of services provided in Canada. APPENDIX B – Guidelines for income and expense waivers involving Regulation 105 withholding.APPENDIX A – Guidelines for treaty based waivers involving Regulation 105 withholding.Income tax conventions or treaties (¶ 98).General information – Enquiries, Web site, forms, and publications (¶ 97).How can the waiver guidelines provide relief? (¶s 91-96).By whom, when, and where is a Regulation 102 waiver application to be presented? (¶s 89-90).To whom do these waiver guidelines apply? (¶s 87-88).Non-resident employee waiver of Regulation 102 withholding.Obligations of the non-resident employee.Director's fees paid to non-residents of Canada (¶s 76-79).Other employee taxable benefits (¶s 73-75).Tax equalization or indemnification (¶ 72).Taxable benefits and other employment income.Regulation 102 withholding, remitting, and reporting (¶s 68-71).Employer-employee relationship – employment services (¶s 65-67).Withholding legislative and administrative framework (¶ 64).Canadian withholding from remunerations paid to non-resident employees.Remuneration from an office or employment provided in Canada by non-resident employees.By whom and in what format are waiver applications to be presented? (¶s 62-63).When are the waiver applications to be presented? (¶s 60-61).To whom do these waiver guidelines apply? (¶ 59).Waivers or reduction of the Regulation 105 withholding based on tax treaty protection or estimated income and expenses.Regulation 105 withholding and Part I instalments (¶s 48-49).Regulation 105 withholding, remitting, and reporting (¶s 41-42).Receiving / lending employer (¶s 35-40).Services performed inside and outside of Canada (¶s 32-34).Types of contractual arrangements or agreements.Goods and Services Tax/Harmonized Sales Tax (¶ 23).Examples of payments not subject to Regulation 105 withholding.Payments to a joint venture or partnership (¶ 22).Payments to a Canadian branch of a foreign entity (¶ 21).Marine and offshore oil and gas industries (¶s 15-20).Withholding paid on behalf of a non-resident (¶ 13).Payments to non-resident artistes and athletes (¶ 11).Examples of payments subject to Regulation 105 withholding.Types of activities subject to Regulation 105 withholding (¶ 10).Types of non resident entities covered by Regulation 105 withholding (¶s 7-9).Canadian withholding from amounts paid to non-residents.Payments for services other than for an office or employment provided in Canada by non-residents.
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