CRA indicates that a fee paid by a non-resident for a service rendered by the Canadian branch of another non-resident is subject to Reg. 105 withholding

CRA indicated that a commission paid by an LLC to the Canadian branch of a related non-resident corporation was subject to Reg. 105 withholding, given that “a ‘branch’ of a non-resident corporation is not a separate legal entity from the non-resident corporation.”

Neal Armstrong. Summary of 22 December 2023 External T.I. 2023-0986461E5 under Reg. 105(1).