CRA finds that a copyright royalty paid for the use of photographs in a TV production is exempted from withholding

CRA considers that payments to a non-resident for the right to use photographs in a TV program enjoy the copyright withholding tax exemption without being excluded under s. 212(5) as a payment for the use of a film.

This is similar to 2013-0514291E5 F, where CRA states that it does not consider that this exclusion will apply where separate copyright royalties are paid to a non-resident for the right to reproduce music which is used in a film.

Neal Armstrong. Summaries of 5 November 2014 T.I. 2013-0506191E5 under s. 212(5) and s. 212(1)(d)(vi).