Canco pays royalties (including a lump sum advance royalty that is non-refundable irrespective of revenues generated) to the U.S. holder of copyright to a play for the right to adapt the play into French and perform it in Quebec. In finding that the royalties were exempt under s. 212(1)(d)(vi), CRA stated:
9730076 and 2003-0018975 … no longer represent the position of the CRA. The practice of the CRA is to the effect that a royalty or similar payment respecting a copyright is not subject to any withholding tax under Part XIII … .