Non-Resident Corporate Tax Services

Specialized Tax Solutions for Non Resident Corporations operating in Canada

Canadian Regulations

At TMP, we specialize in providing non-resident corporations with expert tax solutions in Canada. Our team excels in navigating the intricacies of international tax regulations, assessing your companies CRA tax exposure.
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Corporations

We assist the client with the following

Non Resident Corporate tax filing

NR 303- treaty based exemptions and tax waivers

GST/HST registration for non resident Corporations

Payroll Set-up for Non resident Corporations hiring in Canada

Setting up Canadian Subsidiary for Non-resident parent Corprations

Payments to non resident employees, contractors and shareholders

Transfer pricing analysis and consulting

Regulation 102 and 105 submissions for exemption employees and contractors

Clearance certificate and repatriation of funds

In what situations can a Foreign Corporation become subject to filing requirements and disclosure obligations with the CRA?

Why Us

Financial Education

We prioritize educating our clients, equipping them with the knowledge to make sound financial decisions for their future success.

Seasoned Experts

Our experienced team offers deep expertise, ensuring reliable and comprehensive solutions for all accounting and tax needs.​

Personalized Solutions

Tailoring our services to each client's unique circumstances, we deliver customized solutions that address specific goals and challenges effectively.​

Modern Approach

Embracing cutting-edge technologies and innovative methods, we provide efficient and forward-thinking accounting and tax services to meet the demands of today's business landscape.​

FAQ

The Small Business Deduction is available to Canadian-controlled private corporations, which require non-resident shareholders to own not more than 49% of the common stock of the Canadian corporation.

A non-resident corporation who carries on business in Canada must register for a GST/HST program account when it provides taxable supplies (goods or services) in Canada for over $30,000 a year (the registration threshold). Non-resident corporations can voluntarily register for a GST/HST program account even if they don’t meet the threshold.

“Carrying on business” for GST/HST purposes involves actively engaging in commercial activities in Canada. It’s a complex legal concept, and various factors are considered, such as the extent and nature of the activities, frequency, and scale. Consult the CRA or a tax professional for specific guidance.

 A non-resident corporation must register for a payroll account number with the CRA if it has Canadian employees or withholds Canadian income tax from payments to non-resident employees. The registration is necessary to remit income tax deductions and other payroll-related obligations.

Yes, a foreign company can operate a business in Canada. They can do so by establishing a subsidiary, branch, or through other legal structures. The specific requirements and tax implications depend on the chosen structure.

Yes, a non-resident corporation doing business in Canada is generally required to file a Canadian corporate income tax return, such as a T2 return, to report its Canadian-source income and calculate tax liability.

Yes, a US corporation doing business in Canada is subject to Canadian tax laws and generally required to file a Canadian corporate income tax return if it earns income from Canadian sources. However, per the Canada-US tax convention, a US corporation only needs to pay Canadian tax on profits allocable to a “permanent establishment” in Canada.

income tax purposes?

A US corporation is considered to have a permanent establishment in Canada if it has a fixed place of business in Canada, such as an office, branch, or factory. Additionally, if it has employees or agents in Canada with the authority to conclude contracts on its behalf, it can trigger the concept of a permanent establishment.

The choice between a branch and a subsidiary depends on various factors, including tax implications, liability, and regulatory requirements. Consult with a tax advisor to determine the most suitable structure for your specific business needs.

When hiring and paying non-resident employees in Canada, payers should consider obligations such as withholding and remitting income tax, providing T4 slips, and complying with immigration and employment regulations. Regulation 102 contains certain exemptions for tax withholding from payments to non-resident employees. Consult the CRA and a tax professional for detailed guidance.

When making payments to non-resident contractors for services performed in Canada, payers may have withholding tax obligations (typically 15% of the payments). The specific requirements vary depending on the nature of the services and the tax treaty between Canada and the contractor’s home country. Regulation 105 contains certain exemptions for tax withholding from payments to non-resident contractors.

Thin capitalization rules limit the amount of interest expense a corporation can deduct for tax purposes when it’s excessively indebted to non-residents. These rules aim to prevent profit shifting through excessive interest deductions.

Upstream loan rules are designed to prevent Canadian corporations from taking on excessive debt from foreign affiliates that might not be repaid. There are specific tax implications and restrictions associated with upstream loans. Typically, an income inclusion must be realized by the Canadian corporation for the loan received from foreign affiliates if not repaid within a specified timeframe.

Yes, Canadian corporations are generally required to withhold and remit withholding tax on dividends paid to non-resident shareholders. The withholding tax rate is typically 25% but can be reduced depending on tax treaties between Canada and the shareholder’s home country.

Canadian corporations engaging in intercompany service agreements should follow the arm’s length principle and use transfer pricing methods in accordance with Canadian tax regulations. Methods like the Comparable Uncontrolled Price (CUP) method, Cost Plus method, and Resale Price method are common approaches to ensure transactions are priced at fair market value.

How much will it cost for TMP non-resident Corporate services?

Business number

GST/HST and or payroll Registration

$900-$1300 / CAD

Non-resident Corporate tax filing

$1,500 / CAD

Setting up a Canadian subsidiary

$1,800 / CAD

Special Elections and waivers

$950-$2,000 / CAD

Custom

For more complex preparations, please fill in the questionnaire

Next Steps

Step 1

Please fill in this questionnaire

Step 2

Schedule a consultation with one of our CPAs to receive a final quote and a checklist of the required data

Step 3

Upload requested data onto cloud folder shared

Let’s collaborate!

Have a question, an idea, or just want to learn more about Triple M Professional Corp.? We’re all ears. Fill out the form or Email us and we’ll connect with you soon.

Markham Office
905-237-6424
675 Cochrane Dr East Tower 6th Floor, Markham, ON, L3R 0B6
Toronto Bay Street Office
416-333-1116
401 Bay Street, 16th Floor Toronto, ON, M5H 2Y4
San Francisco Office
415-366-5667
590 California Street 16th Floor, San Francisco, CA 94104
New York Office
212-651-9101
555 Madison Ave 5th Floor Manhattan,
NY 10022
Toronto King Street West Office
416-333-1116
100 King Street West, Suite 5600, Toronto, ON, M5X 1C9
Markham Office
905-237-6424
675 Cochrane Dr East Tower 6th Floor, Markham, ON, L3R 0B6
Toronto Bay Street Office
416-333-1116
401 Bay Street, 16th Floor Toronto, ON, M5H 2Y4
San Francisco Office
415-366-5667
590 California Street 16th Floor, San Francisco, CA 94104
New York Office
212-651-9101
555 Madison Ave 5th Floor Manhattan,
NY 10022
Toronto King Street West Office
416-333-1116
100 King Street West, Suite 5600, Toronto, ON, M5X 1C9