CRA Begins Dialogue with CAPACOA on International Taxation

The Performing Arts Tax Working Group met with representatives of the Canada Revenue Agency on March 2, nearly a year after the group’s initial request. The meeting laid the grounds for a constructive dialogue between all parties.

The meeting was very cordial in tone. Discussions focussed on principles, factual information and big-picture issues rather specific cases. This enabled parties to explore the whole range of issues – and potential solutions – associated with international taxation.


The de minimis rule – the idea that something presents a very low risk and is therefore insignificant – was an overarching theme for the meeting. With this principle in mind, many exclusion mechanisms were considered, in addition to the Legislative Proposals which are currently being studied by government to reduce the burden of second-level taxation for non-resident employers. Some scenarios may require changes to the Canada Income Tax Act, in which case Finance Canada will also need to be involved.


The CRA expressed a willingness to collaborate with the Working Group, and is supportive of the Working Group’s streamlining efforts. The CRA also provided useful clarification on the waiver application process. This information was added to CAPACOA’s International Taxation pages.


The Working Group prepared and presented a document of statistical information on the Canadian Performing Arts Sector and Non-Resident Artists. More information sharing will take place over the next weeks and up until our next meeting, in May.

Thank you to CAPACOA for providing this information.