The CRA concluded that Canco was not required to withhold from incentive amounts paid to the non-resident employees of dealers of Canco’s profits. The incentive amounts amounts related to warranties registered on Canco’s products. The CRA, however, stated that Canco was required to file a T4A in respect of the payments. Marlene Cepparo, “Information Returns but No Withholding Tax” 23:12 Canadian Tax Highlights (December 2015) re technical interpretation 2013-0495611E5 dated September 24, 2015. Ms Cepparo’s article contains a useful summary of the relevant statutory provisions.
