C. PAYMENTS TO NON-RESIDENTS NOT CARRYING ON BUSINESS IN CANADA

摘要

Paragraph 212(1)(d) of Part XIII of the Act imposes an income tax of 25% on the gross amount of a rent, royalty or similar payment paid or credited by a resident of Canada to a non-resident. The 25% rate of Part XIII tax may be reduced pursuant to the provisions of an income tax convention between Canada and the country of residence of the non-resident. A resident paying the amount is required to deduct or withhold the amount of the tax from the payment and remit that amount to the Receiver General for Canada on behalf of the non-resident person "notwithstanding any agreement or law to the contrary".