Treaty does not specify a rate: If a treaty does not specify a rate for a particular type of income, a rate of 25% is imposed by Canada and indicated below. Other rules may apply to payments arising in the other state.
Interest: The rates are those noted in a treaty for related-party interest. Effective 2008, Canadian withholding tax is eliminated on interest (except for "participating debt interest") paid to arm's length non-residents.
Dividend: If two or more rates are provided, the lower (lowest two in Vietnam) rate applies if the recipient is a company that owns/controls specified interest of the payor.
Estate or trust: Some treaties specify that the reduced withholding rate for:
- trust income does not apply if contributions to the trust were deductible; and/or
- estate or trust income applies only if the income is taxable in the recipient's country of residence.
If the rate indicated below for estate or trust income is 15% or 25%. the treaty specifies a 15% rate for trust income and no rate for estate income. In such cases, a rate of 15% may apply on estate income (rather that the maximum Canadian withholding tax rate of 25%) because in some circumstances a trust indicates an estate.
Lump sum pension: applicable to lump sum withdrawal from:
- RRIF (amounts greater than 2x minimum or 10% of value at Jan 1)
- withdrawal of commuted value from registered payout annuity at death
Periodic pension: applicable to annuity payments from registered source
- RPP - scheduled payments
- DPSP - scheduled payments
- RRIF - 2x minimum or 10% of value at Jan 1, whichever is greater
- Payout annuities - RPP, DPSP, RRSP scheduled payments
Lump sum annuity: applicable to the taxable portion of:
- non-registered AA/IA if the annuitant was a non-resident at issue
- non-registered payout annuity - commuted value
Periodic annuity: applicable to taxable portion of scheduled payments from non-registered payout annuity
Foreign income: applicable to foreign non-business income and foreign interest from non-registered foreign outside SPIO only