Franchise renewal fees are subject to Part XIII tax

Franchise renewal fees paid on a cross-border basis are considered by CRA to be "rents, royalties or similar payments" and, therefore, are subject to Part XIII tax under s. 212(1)(d) on general principles.

Neal Armstrong. Summary of 27 March 2014 T.I. 2013-0512921E5 under s. 212(1)(d).