Using a secondment arrangement may reduce complications when a non-resident provides the services of an employee to a Canadian affiliate

A non-resident who is assigning one of its non-resident employees to Canada may be able to avoid setting up a payroll account with CRA, and being considered to carry on business in Canada, by "seconding" (loaning out) the employee to its Canadian affiliate (Canco) in accordance with the IC-75-6R2 guidelines, so that Canco is treated by CRA as the employer and is "responsible" for the Canadian source deductions – even though the employee stays enrolled with the non-resident’s pension, equity compensation and other benefit plans. In particular, Canco may not have to actually pay remuneration to the seconded employee, so that the non-resident charges Canco for the employee's services and the charge-back (which ideally is reduced by the amount of the Canadian source deductions) is used by the non-resident to pay the seconded employee’s remuneration.

Neal Armstrong. Summary of Ron Choudhury, "An Overlooked Solution for Non-resident Employers", Taxation of Executive Compensation and Retirement (Federated Press), Vol. 24 No. 7, September 2015, p. 1643 under Reg. 104(2).