If a non-Canadian corporation’s employees physically provide services in Canada, the non-Canadian corporation has Canadian payroll withholding tax responsibilities and obligations.
While not exhaustive, examples of such services include: construction projects, installation projects, manufacturing or processing, oil and gas operations, entertainment, athletic events, forestry, consulting, legal or accounting services, engineering, lecturing and conference presentations.
There may be some planning opportunities here. The non-Canadian corporation may be able to apply for a one-off tax waiver for a limited period of time or a blanket waiver absolving it from Canadian payroll obligations (two-year period) under certain circumstances. More information can be obtained at www.crowe.com and from your local Crowe tax contact.
If you have any questions, please contact: [email protected]