The exposure on this kind of filing is charged by reference to the form and the delay rather than to the tax, which is the part payers find counter-intuitive. A year in which the correct amount was withheld and remitted, or in which no tax was ultimately due at all, can still carry a charge simply because the slips went in after they were due. That also means the variable you can still influence is the delay. Once you know slips are outstanding, the useful step is to prepare and file them rather than to wait until the whole position is tidy.
What is the late filing penalty for Form T4A-NR?
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The slip reporting fees, commissions and other amounts paid to non-residents for services performed in Canada. The exposure on this kind of filing is charged by reference to the form and the delay rather than to the tax, which is why an unfiled year with no tax can still be expensive.
What a late filing costs
The slip reporting fees, commissions and other amounts paid to non-residents for services performed in Canada.

When the rule breaks
Where the work was physically done is the test. Withholding applies to services rendered in Canada even where the contract, the invoice and the bank account are all foreign, and even where a treaty will ultimately relieve the tax.
Where to go from here
The full treatment — who it binds, the deadline, the penalty and the fixed fee — is on T4A-NR — services rendered in Canada. One call is usually enough to know whether this is a filing or a project.
Reviewed for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. General information, not advice for your circumstances — call our 24-hour helpline to discuss your own position.
Cross-border tax case studies
Two years of slips reconstructed after a bookkeeping handover
A payer discovered during a change of bookkeeper that non-resident services slips had never been issued for two earlier years, although the payments were plainly in the ledger. We rebuilt each engagement from invoices, travel records and the contracts, identified the payments that related to work performed in Canada, and filed the outstanding slips for both years. The delay was the part of the exposure that could still be limited, so the filings went in before the analysis was polished and a memorandum recorded the basis used. The payer now issues slips as part of its year-end routine.
Read how this one runsEnquiry answered where a waiver had been mistaken for an exemption
A payer was asked why no slips had been filed for a year in which withholding had been waived. It had read the waiver as removing the whole obligation. We filed the slips, set out in the reply why the reporting and the withholding are separate questions, and attached the waiver correspondence so the file explained itself. The engagement produced a completed filing for the year and a short written procedure that keeps the two questions apart the next time a waiver is obtained.
Read how this one runsWithholding remitted for years but no slips ever filed
A payer had been remitting withholding on non-resident contractor fees for years and had assumed the remittances were the filing. They were not. We reconciled the remittance record to the underlying payments, resolved the differences that came from foreign currency conversion dates, and filed the missing slips year by year against that reconciliation. Because the money had always been remitted, the exposure was about delay in reporting rather than unpaid tax, and the reconciliation is what let the payer show that clearly.
Read how this one runsAmended slips after gross fees had been reported net of costs
A payer had reported non-resident contractor fees after deducting reimbursed travel and an agent's commission, so the amounts on the slips did not match the gross fees paid. We recalculated the reportable amounts from the contracts and the payment records, amended the affected slips, and documented the difference between the original and the corrected figures. The correction was filed with an explanation of how it had arisen, which is the part that distinguishes an error being fixed from a filing that was simply ignored.
Read how this one runsFirst non-resident engagement found during audit preparation
A growing company engaged a non-resident specialist for the first time and only learned during preparation for its year-end audit that a reporting obligation had arisen and passed. We established which of the specialist's work had been performed in Canada, prepared the slip, and filed it alongside the year's other obligations. The auditors received a written note on the treatment and on the timing. The company's contracting template was then changed so the information needed for a slip is collected when a non-resident supplier is taken on.
Read how this one runsExposure mapped before filing where a demand had been received
A payer with a history of a demand to file in an earlier year wanted to know where it stood before putting several years of outstanding slips in. We set out the exposure by reference to the form, the delay and the years actually affected, distinguished the charges that attach to reporting from those that attach to tax owing, and separated the years where the higher rate could be reached from the years where it could not. The payer then filed with the position quantified in advance rather than discovering it afterwards.
Read how this one runsTen Years of Missed Returns Filed as One Engagement
Filing many years at once is a sequencing problem: carry-forwards, instalments and credits from the earliest year feed the latest. Filing them out of order is what turns a recoverable position into an assessed one.
Read how this one runsA Clean History Used to Remove a First Penalty
An administrative waiver can remove a first failure where the filing and payment record supports it, and it is spent once used. Whether to claim it now or keep it for a heavier year is a judgement made with the whole file in view.
Read how this one runsAll case studies — every published engagement in one place.
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Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.
A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.
- Reg 105 / 102 waivers
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- Governance & substance
The follow-up questions on Form T4A-NR
Yes, that can still happen. The reporting obligation and the tax obligation are separate, and the charge for filing a slip late attaches to the reporting. It is decided by the facts of the engagement rather than by the tax owing, which is why a nil position does not remove it. Payers who obtained a waiver sometimes read the waiver as the end of the matter. It deals with what has to be withheld, not with what has to be reported. Keep the waiver correspondence with the filing, because it explains the withholding and does not excuse the slips.
For the 2025 tax year the CRA's late-filing penalty on a return is 5 per cent of the balance owing, plus 1 per cent of that balance for each full month the return is late, to a maximum of twelve months. That charge is measured on tax owing, so it is a different measure from the charge for filing information slips late, and the two should not be mixed when you are quantifying an exposure. Note also that the penalty itself does not compound. Interest is what compounds, daily, on whatever remains unpaid.
No, and that belief has caused payers a great deal of wasted worry. Repetition alone is not the trigger. For the 2025 tax year the higher rate applies where the CRA issued a demand to file and charged a late-filing penalty in any of the three preceding tax years. In that case the return penalty is 10 per cent of the balance owing plus 2 per cent of it for each full month, to a maximum of twenty months. Twelve months becoming twenty is not a doubling of the period, and a second late filing with no demand behind it does not reach the higher rate at all.
The penalty does not compound. Interest compounds daily on an unpaid balance, which is a different thing, and it is the reason a small liability left alone grows in a way that looks like compounding penalties. For the payer this matters practically. Paying what is owed stops the interest running on it, even while the paperwork behind it is still being put together. Filing the outstanding slips deals with the reporting side. Doing both is what closes the year. Doing neither because you are waiting for a complete picture is the expensive option.
File. The charge on a late information filing is driven by the form and the delay, so waiting adds to the only part of the calculation still within your control. In practice the work is to reconstruct what was paid to each non-resident, decide which payments related to services performed in Canada, and prepare the slips on that basis. Where the records are thin, a documented reasonable reconstruction filed now is a better position than a perfect one filed a year later. We agree the fee for that work in writing before it starts.
A taxable presence in another country under the treaty — typically a fixed place of business such as an office, branch, factory or workshop, or a dependent agent habitually concluding contracts on your behalf. Some treaties add a services test measured in days. Purely preparatory or auxiliary activity is excluded, but that carve-out is narrower than it sounds: one senior employee working from home in the other country, with authority, has been enough. See business profits and permanent establishment.
Both countries have routes back, and using one before they contact you is what preserves the relief. On the US side there are procedures aimed at taxpayers whose failure was not wilful, including one designed for people living outside the country, and separate procedures for late account reports and information returns alone. Canada has its voluntary disclosures programme and taxpayer relief for penalties and interest. Filing quietly and hoping is the one approach with no protection attached to it. See catch-up filing.



