Is the summary late if the slips went in on time?
It can be. The slips and the summary do different jobs. The slips report what each non-resident was paid, while the summary reconciles those slips to what was remitted, and filing one does not discharge the other. Exposure on this kind of filing is charged by reference to the form and the delay rather than to the tax, so a year in which every dollar was withheld and remitted correctly can still carry a charge if the reconciling document went in late. If the slips are filed and the summary is not, the summary is the thing to deal with now.
What is the CRA late filing penalty and does it apply here?
The figure most people have in mind is the penalty on a return, which for the 2025 tax year 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 is measured on tax owing. A late information filing is charged by reference to the form and the delay instead, which is why an unfiled year with no tax can still be expensive. Quantify the two separately. Borrowing the return figures for a slip or a summary produces a number that is not the right one.
Our summary was on time but the totals were wrong, is that late?
No, those are different failures. Filing after the due date is a matter of delay. Filing on time with totals that do not reconcile is a matter of accuracy, and the answer to it is an amended summary prepared from the underlying payments rather than from the original totals. What makes an inaccurate filing worse is leaving it, because the difference then has to be explained years later from records that have moved on. Identify the reconciling items, correct them, refile, and keep a note of how the original figures arose.
Does interest run on top of a late filing charge?
Interest compounds daily on an unpaid balance. The penalty itself does not compound, so what grows over time is the interest on whatever is outstanding. For a payer the practical consequence is that settling the amount owed and completing the outstanding filings are two separate pieces of housekeeping, and each one stops a different thing running. Waiting until both can be done together is common, and it is usually the more expensive choice, because the interest does not pause while a reconciliation is being finished.
A waiver covered part of the year, does that reduce the charge?
Not the charge for filing late. A waiver deals with what has to be withheld. It does not deal with what has to be reported, or when. It does change the work, though. Where a waiver was granted mid-year, the summary is where the pre-waiver and post-waiver periods have to agree, so a late summary in a waiver year usually needs the year split at the date the waiver took effect before it can be reconciled at all. Keep the waiver correspondence with the filing, so the withholding pattern across the year is explained on its face.
We are catching up several years of summaries, where do we start?
Start with the remittance records rather than the slips, and work one year at a time. Each year's summary has to agree with the slips issued for that year and with the amounts remitted under the account those remittances went to, so a year cannot be closed out of the totals of its neighbours. Where the entity itself changed during the period, allocate before you reconcile. File each year as it is finished rather than holding the set back for the last one, because delay is the part of the exposure still within your control.
Is "fund transfer pricing" the same thing as transfer pricing?
No — and if you came here to calculate FTP, this is not it. Fund transfer pricing is a bank's internal allocation of funding costs and benefits between its own business units, a treasury and asset-liability management discipline used to measure branch or product profitability. Tax transfer pricing is about prices between legally separate related parties across borders, and about which country taxes the resulting profit. The words overlap; the fields do not. See our transfer pricing work.
How do families with assets in two countries handle inheritance?
With paperwork built for both systems rather than one. In practice that means wills that work where each asset actually sits, an executor with authority a foreign bank or land registry will accept, clearance certificates before the estate distributes so the executor is not left personally exposed, and an estate tax exposure calculation done while the person is alive and can still act on it. Doing it afterwards costs more and forecloses most of the options. See cross-border wills and trusts.
