In Olympia Trust Company, 2014 TCC 372, the Tax Court of Canada held that the trustee (Olympia) of a self-directed registered retirement savings plan (RRSP), was liable under section 116 of the Income Tax Act (Canada) for withholding tax that was not remitted by or on behalf of non-resident vendors in the context of the sale of shares that were taxable Canadian property (TCP) where such shares were to be held as property of the RRSP.
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While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort