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Tax Alert 2026 No. 34, 12 June 2026
On 12 June 2026, the Canada Revenue Agency (CRA) announced that it is further extending the administrative relief from Regulation 105 withholding tax on subcontractor fees reimbursed to non-residents that it previously granted, from 30 June 2026 to 31 March 2027.
This relief has been granted in respect of the CRA’s new position announced in June 2024 that requires Canadian resident corporations to withhold tax on subcontractor fees reimbursed to non-resident corporations for services performed in Canada, effective for subcontractor fees reimbursed after 30 September 2024.
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Issue No. 34, 12 June 2026
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Previous issues
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Bill C‑31, Budget 2025 Implementation Act, No. 2, received first reading on 6 May 2026 and contains significant — though mostly previously announced — proposed amendments to Canada’s Global Minimum Tax Act (GMTA) and Income Tax Act.
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