Government of Canada / Gouvernement du Canada
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Income Tax Regulations

Version of section 105 from 2009-11-19 to 2024-05-01:

  •  (1) Every person paying to a non-resident person a fee, commission or other amount in respect of services rendered in Canada, of any nature whatever, shall deduct or withhold 15 per cent of such payment.

  • (2) Subsection (1) does not apply to a payment

    • (a) described in the definition remuneration in subsection 100(1);

    • (b) made to a registered non-resident insurer (within the meaning assigned by section 804); or

    • (c) made to an authorized foreign bank in respect of its Canadian banking business.

  • [NOTE: Application provisions are not included in the consolidated text
  • see relevant amending Acts and regulations.]
  • SOR/94-686, s. 49(F)
  • SOR/2009-302, s. 1

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