CRA’s COVID guidelines do not include dispensation from source deductions for non-resident employers whose employees work from Canada due to travel restrictions
CRA indicated that where an employee not ordinarily resident in Canada is present in Canada due to COVID-related travel restrictions and works remotely (for the non-resident employer) from Canada, the nonresident employer would now be subject to Canadian withholding obligations (including where the employer did not consent to this work occurring in Canada) unless a waiver of withholding was obtained – including in the situation where it did not consent to this Canadian nexus? However, CRA would seek to be flexible when withholding problems were encountered, as extraordinary circumstances can make compliance difficult.
Neal Armstrong. Summary of 2020 IFA-YIN Seminar on COVID-19 Guidelines, Q.3 and Q.4 under s. 153(1)(a).