A Canadian real estate agent paid a portion of its commission generated on a sale of Canadian real estate (occurring between resident Canadians) to a UK-resident broker for services of that individual (performed in the UK, without travelling to Canada) which contributed to the sale, including financial analysis and participating in conference calls. CRA stated
[A] commission paid to a non-resident of Canada is not subject to withholding tax under ITR subsection 105(1) if all of the services rendered by the non-resident are performed outside Canada.