Who files Form T2 Schedule 29?

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Answer

Canadian corporations paying interest, royalties, management fees, rent or service fees to non-residents. The obligation is decided by facts rather than by tax owing, which is why a nil position does not remove it.

The rule on who files

Canadian corporations paying interest, royalties, management fees, rent or service fees to non-residents.

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The exception

This schedule and the non-resident slips have to tell the same story. Where they do not, the follow-up is usually about whether withholding was applied at the right rate — or at all.

Who files Form T2 Schedule 29?
ItemAmount
Cost of the propertyC$347,000
Value on the departure dayC$718,290
Accrued gain treated as realisedC$371,290
Amount assumed to enter incomeC$185,645
Tax at an assumed 30%C$55,694

C$55,694 becomes payable in a year with no sale and no cash. That is what makes the departure date a planning variable: losses realised before it, an election to defer payment against security, and defensible valuations for anything private all change this number.

Treat these numbers as a worked example rather than advice — they exist to make the mechanics visible, and the rates and thresholds are assumed for the illustration. For a real filing, we verify each figure with the authority that publishes it, for your year.

How to get this moving

The full treatment — who it binds, the deadline, the penalty and the fixed fee — is on T2 Schedule 29 — payments to non-residents. One call is usually enough to know whether this is a filing or a project.

Checked and signed off for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. Published as general information. For a position on your own file, call the 24-hour helpline.

Who needs to file FATCA, in practice

People reach this page searching for who needs to file FATCA. It is covered here as it applies to Form T2 Schedule 29 — who it applies to, what has to be filed, and what it costs, at a fixed fee agreed before the work starts.

Cross-border situations we are engaged for

Case study 1

Service fees to a foreign parent reported after a contract review

A Canadian subsidiary had been paying its foreign parent for development work since incorporation and had never treated the payments as reportable, on the view that they were a cost recharge. We went back through the intercompany ledger and the underlying invoices, characterised each payment by what was actually supplied, and separated the service fees from amounts that were reimbursements of third-party costs. The schedule was then prepared for each affected year and filed with a memorandum recording how each category had been determined. The engagement produced a documented characterisation the company can apply to the same payments every year.

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Case study 2

Reconciling the schedule against the non-resident slips before filing

A company had produced its schedule and its non-resident slips from two different sets of working papers, one gross and one net. The engagement was a reconciliation. Every payment was traced from the ledger to the slip and to the schedule line, with the gross-up applied consistently and timing differences between accrual and payment identified. Where a figure could not be reconciled we went back to the underlying contract rather than adjusting it to fit. The output was a schedule and a set of slips that describe the same payments in the same way, and a working file that shows why.

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Case study 3

Interest on a shareholder loan found in the intercompany account

The corporation's accounts carried a long-standing balance owed to a non-resident shareholder, with interest accrued annually and never paid out. Nobody had treated it as a payment, so it had never reached the schedule. We reviewed the loan agreement and the accounting entries, established when interest had been credited to the shareholder's account, and treated those entries as the relevant events rather than waiting for a cash transfer. The schedule was prepared on that basis and the withholding position reviewed for the same years. The engagement produced a filed position on the loan the company can stand behind.

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Case study 4

Rent paid to a non-resident landlord through a property manager

A corporation leased its premises through a property manager and had assumed the manager's involvement settled the reporting. The landlord was not resident in Canada. We established who the payments were ultimately made to, obtained confirmation of the landlord's status, and traced the amounts the manager had remitted against the amounts the corporation had paid. The schedule was then filed for the years concerned and the withholding on the rent reviewed alongside it. The work produced a clear record of the chain of payment and a standing instruction about what the finance team collects from the manager each year.

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Case study 5

A royalty paid net of withholding at a treaty rate

A licensor outside Canada was paid a royalty net of tax withheld at a treaty rate, and the company had reported the net figure. The engagement was to establish the gross amount, confirm the basis on which the reduced rate had been applied and the evidence held for it, and restate the schedule on a gross basis with the withholding shown separately. Where the supporting documentation for the treaty position was thin, we said so rather than presenting it as settled. The result was a schedule consistent with the slips and a note of what the company needs on file in future.

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Case study 6

Documenting a nil position for a newly incorporated subsidiary

A newly incorporated subsidiary believed it had made no reportable payments in its opening year, but the group's shared-service arrangements made that worth testing rather than asserting. We reviewed the intercompany accounts, the service agreements in place and the entries settled by set-off, and confirmed that nothing within the reportable categories had been paid or credited in the period. The conclusion was recorded in a short file note setting out what was examined and why nothing arose. The engagement produced a documented nil position rather than an unexamined assumption, and a checklist for the following year.

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Case study 7

An Indian Company Paying a Foreign Supplier

Payments abroad carry deduction at source and a certification filed before the money moves. Whether the treaty reduces the rate depends on what is being bought, and the classification is the decision the whole filing rests on.

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Case study 8

Withholding Reduced by the Right Article

Dividends, interest and royalties each have their own article and their own rate, and the payer applies whichever it is satisfied of. Establishing entitlement before payment is what secures the lower rate at source.

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All case studies — every published engagement in one place.

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Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

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Asked next about Form T2 Schedule 29

Do we file Schedule 29 if we withheld nothing on the payment?

Yes. The schedule reports the payment, not the withholding. A Canadian corporation that pays interest, royalties, management fees, rent or service fees to a non-resident reports those payments, and the fact that nothing was withheld is a separate question. It is usually the harder one. Where no withholding was applied we want to know why before the schedule goes in: a treaty rate relied on, an exemption claimed, or simply an oversight nobody has looked at since. The schedule is often what makes the omission visible, so it is better to have the explanation settled at the same time as the filing than to assemble it after a letter arrives.

Does a management fee paid to our foreign parent belong on Schedule 29?

Usually yes. Management fees paid to a non-resident are one of the payment types the schedule is built to capture, and a payment to a parent company is still a payment to a non-resident. Two things tend to go wrong. The fee is booked to an intercompany account and settled by set-off rather than by transfer, so nobody treats it as a payment at all. Or it is described as a recharge of costs, and the description is taken to change its character. Neither removes the reporting. Work from what the payment is actually for, then report it on that basis.

We had a loss year with no tax payable. Is Schedule 29 still required?

Yes. The obligation follows the payments made during the year, not the corporation's tax position. A loss year with no balance owing removes nothing, and a dormant corporation that still paid a royalty or a management fee to a non-resident sits in exactly the same place as a profitable one. The practical risk with a loss year is that the file gets less attention, the schedule gets skipped, and the omission then sits in the record for as long as the return does. Prepare it on the same timetable as the rest of the return rather than treating it as optional detail.

What happens if Schedule 29 does not match the non-resident slips?

That is the follow-up we see most often. The schedule and the slips are two descriptions of the same payments, and where they disagree the question that arrives is about withholding: whether it was applied at the right rate, or at all. The disagreement is often innocent. Amounts entered gross in one place and net in the other, a payment recorded in the month it was accrued rather than paid, a credit note taken against the wrong year. It is still what starts the correspondence. Reconcile the two before filing, and keep the working that shows they agree.

Is rent paid to a non-resident landlord reported on Schedule 29?

Rent paid to a non-resident is one of the payment categories the schedule covers, so a Canadian corporation paying rent to a landlord who is not resident in Canada should expect to report it. The point that causes trouble is the amount. Where tax was withheld and the landlord was paid the balance, the figure that reaches the schedule has to be the gross rent rather than the sum that left the bank account, with the withholding shown separately. Booking the net figure is how a schedule ends up disagreeing with the slips for the same year, and that disagreement is what prompts the question about whether the right rate was applied.

Our T2 was filed without Schedule 29. How do we fix it?

The schedule is prepared for the year it belongs to and put in front of the CRA with the return it should have accompanied. Before that, reconcile it against the non-resident slips for the same year, because a correction that disagrees with the slips invites the query it was meant to close. Where the review shows withholding was short, deal with that at the same time rather than in a second round. Coming forward with the schedule, the reconciliation and an explanation is a materially different conversation from answering a letter about the same gap months later.

How would a foreign tax authority know I am resident there?

Mostly from information you or your bank already provided. Account-opening forms ask you to self-certify tax residence, and that certification is reported between authorities under the Common Reporting Standard or, for US accounts, under the FATCA framework. Beyond that: employer and payroll filings, property registries, immigration records and the tax filings of anyone who paid you. The realistic planning assumption is that the data arrives. See FATCA and information reporting.

What is Part XIII withholding?

Canada's flat withholding on certain payments to non-residents — dividends, interest to related parties, rents, royalties, pension and annuity payments, management fees. The payer withholds and remits, and is liable if they do not, which is why they insist on documentation. A treaty can reduce the rate, but only where the recipient has given the payer the declaration establishing entitlement before payment. Where too much was withheld, a refund claim is the route, with its own time limit. See Part XIII withholding review.

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