In response to a question that noted that subsequent to the issuance on 19 September 1985 of a Special Release amendment to IT-303 which "generally concluded that the exemption in subparagraph 212(1)(d)(vi) was limited to payments which are considered under the Copyright Act of Canada to be in respect of a production or reproduction of a literary, dramatic, musical or artistic work" (see 13 June 2003 T.I. 2003-0018975 and 29 May 1998 Memorandum 973007), CRA stated:
The Agency is currently following IT-303SR and at this time, pursuant to subparagraph 212(1)(d)(vi) of the Act, will not be reassessing to tax under Part XIII any payments in respect of a copyright of a literary, dramatic, musical or artistic work (unless it is payment that falls under subsection 212(5) of the Act). As such any payments in respect of the copyright of a literary, dramatic, musical or artistic work, including the right in respect of the translation, performance, telecommunication or broadcast of one of the aforementioned works will not be subject to withholding tax unless that payment is for a right in or the use of a motion picture film or a film or video tape for use in connection with television that is to be used or reproduced in Canada.