A recent technical interpretation released by the Canada Revenue Agency (CRA) confirms the CRA's position that withholding tax under paragraph 212(1)(d) of the Income Tax Act (Canada) (ITA) does not apply to lump-sum payments made to a non-resident of Canada for exclusive distributorship rights and also serves as a reminder to taxpayers of the breadth of the restrictive covenant provisions in the ITA.
July 12 2018