28 January 1993 T.I. (Tax Window, No. 28, p. 9, ¶2403)

Where, under French tax law, a Canadian-resident artistic loan-out corporation effectively is disregarded so that the artist is considered to be directly taxable, a French withholding tax of 15% on the gross income of the loan-out corporation will not give rise to a Canadian foreign tax credit because the artist is the only person legally liable for the French tax.

A Canadian-resident loan-out corporation will be required to make deductions at source on any salaries paid to the artist-employee even though the salary pertains to services rendered outside of Canada that may be taxable in the country where the services are rendered.