22 February 2011 External T.I. 2010-0374421E5 - Motion Picture Copyright Royalties -- summary under Article 12

The exemption in the Canada-US Convention for royalties paid for the reproduction of motion picture films (in this case, on videos) for private home use rests on the 1984 US Treasury Explanation to that Convention. In the case of other similarly-worded treaties, such as those with the UK, France and Thailand, this interpretation does not apply so that such royalties are subject to Treaty-reduced rates of Part XIII tax (of 10%, 10% and 15%, respectively, in the case of those three countries) rather than being exempt.