CRA indicates that lump sum RRSP payments to a New Zealand resident are subject to Part XIII tax at a 25% rate

CRA noted that, although IC76-12R6 stated up until its correction on June 21, 2021 that a lump sum RRSP payment to a resident of New Zealand was subject to a 15% Canadian withholding tax, under the current New Zealand-Canada Treaty that became effective on August 1, 2015, the reduced 15% Canadian withholding tax rate under Art. 17 only applies to periodic pension payments, and lump sum RRSP payments to New Zealand resident are subject to Part XIII withholding at the rate of 25% under s. 212(1)(l).

Neal Armstrong. Summary of 22 December 2021 External T.I. 2021-0878661E5 under Art. 18.