Tax memo: Withholding tax on royalty payments to a sister company

View this page in: Français

How paragraph 18(1) and section 247 of the ITA interact

A recent CRA audit position illuminates the interaction of paragraph 18(1)(a) and section 247 of the Income Tax Act (ITA), and raises potential withholding tax issues for some companies that pay royalties to related companies in the United States.

Learn about the CRA’s audit position and read our analysis.