Non-Resident Tax Services

Regulation 105 Withholding Refund — Recover Your 15%

Canadian clients are often required to withhold 15% on payments to non-residents for services in Canada. In most cases, this is not a final tax—it’s a prepayment we can help you recover.

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15% withheld?
Services in Canada?
Non-resident?
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Let's check your eligibility.

First, tell us about your company entity.

Our Process

How the Refund Process Works

Strict deadlines apply. We guide you through every step of the CRA filing process.

1

Eligibility Check

Free instant assessment.

2

Secure Upload

Encrypted portal transfer.

3

Analysis

Detailed treaty review.

4

Filing

T2 & Schedule 91 submission.

5

Refund

Refund issued by CRA.

Documents Required for Tax Recovery

To file your T2 return and Schedules 91/97, we simply need the core documents proving your income and non-resident status.

  • Withholding proof (NR4, T4A-NR, or Payer Letter)
  • Contract or Statement of Work
  • Invoices related to the Canadian work
  • Travel dates (flight tickets or calendar log)
  • CRA Business Number (if you have one)
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Regulation 105 Waiver Application

Want to stop the 15% deduction before it happens? Eligible non-residents can apply for a Regulation 105 Waiver before work begins.

Request a Waiver Review

Technical Specifications & Common Pitfalls

VSReg 105 vs. Reg 102

Many businesses confuse the two. Regulation 105 applies to fees paid to a non-resident for services rendered in Canada.

Regulation 102 applies to salaries/wages paid to non-resident employees working in Canada. Each requires a different waiver (R105 vs R102) and a different T2 vs T4 filing process.

Treaty Returns & Article VII

Most refunds are claimed under Article VII (Business Profits) of the Canada-US Tax Treaty (or similar international treaties).

The argument is simple: without a "Permanent Establishment" (fixed place of business) in Canada, the profits are taxable only in your home country, meaning the 15% withheld in Canada must be returned.

Common Questions

Regulation 105 FAQ

What is Regulation 105 withholding?
Regulation 105 of the Canadian Income Tax Act requires payers to withhold 15% of gross payments made to non-residents for services rendered in Canada. This is a tax prepayment, not necessarily the final tax liability.
Why did my Canadian client withhold 15% from my invoice?
They are legally required to do so by the CRA if you are a non-resident performing services in Canada. If they fail to withhold, they can be held personally liable for the tax plus penalties.
Is the 15% a final tax or a refund?
It is a prepayment on potential Canadian tax liability. If your final tax liability is lower than the withheld amount (which it often is for treaty-protected non-residents), you can claim a refund for the difference by filing a Canadian tax return.
Can I get a refund if I have no permanent establishment (PE) in Canada?
Yes. In fact, not having a PE is often the basis for claiming a full refund under a tax treaty. You generally still need to file a T2 return (Treaty-Based Regulation 105 Refund) to prove this status and request the funds back.
What are Schedule 91 and Schedule 97?
Schedule 91 outlines the 'Information Concerning Claims for Treaty-Based Exemptions,' and Schedule 97 lists 'Additional Information on Non-Resident Corporations in Canada.' These are key forms filed with your T2 return to claim treaty benefits.
What if services were performed in Québec?
Québec has its own additional withholding requirement of 9% for services rendered in the province by non-residents. This is administered by Revenu Québec and requires a separate filing process to recover.
What documents do I need to start?
At a minimum, you'll need proof of the withholding (NR4 slip or letter from payer), your invoices, and details of the service dates/locations. If you don't have an NR4 yet, we can sometimes proceed with alternative proof.