Yes. The obligation falls on Canadian payers who issued non-resident services slips during the year, and one slip makes you one of them. There is no threshold below which the summary is optional, because the summary is not a report of size. It is the document that reconciles the slips to what was remitted. With a single slip the work is short, but it still has to be done, and the total on the summary has to agree with the slip you issued. A nil position on tax changes none of this.
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Canadian payers who issued non-resident services slips during the year. 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 payers who issued non-resident services slips during the year.

When it does not bind you
It ties the payer's records to what the CRA received. Where a waiver was granted mid-year, the summary is where the pre-waiver and post-waiver periods have to agree.
Where to go from here
The full treatment — who it binds, the deadline, the penalty and the fixed fee — is on T4A-NR summary. Ask before the move rather than after it, because most of the useful options expire on the date.
Read and approved for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. Published as general information. For a position on your own file, call the 24-hour helpline.
Cross-border situations we are engaged for
Mid-year waiver split into two reconciling periods
A payer obtained a waiver part-way through the year and filed a summary that reconciled the year as a single block. The totals balanced, but the withholding before and after the waiver did not. We split the year at the date the waiver took effect, reconciled each period against the slips and the remittances that belonged to it, and refiled the summary on that basis. The engagement produced a two-period reconciliation the payer keeps with the waiver correspondence, so the year explains itself without anyone having to reconstruct it.
Read how this one runsTwo remittance accounts after an amalgamation brought into agreement
Following an amalgamation, a payer had remitted non-resident withholding under both the predecessor account and the continuing one within a single calendar year. Slips had been issued from one set of records and remittances made from two. We allocated each payment to the account its remittance had gone to, reconciled the slips against each account separately, and prepared a summary for each. The work produced a filed reconciliation per account and a note of the allocations used, which mattered when the predecessor's account was later closed.
Read how this one runsSlips exceeded remittances because of conversion dates
A payer's slips totalled more than the year's remittances and nobody could see why. The difference came from foreign currency. The ledger converted each invoice at the date it was booked, while the remittances had been calculated at the payment date. We identified every affected payment, set out one consistent basis of conversion, restated the slips where they were wrong, and reconciled the summary to the remittance record. The payer now applies a single documented conversion policy across the year.
Read how this one runsFees recorded net of an agent's commission grossed back up
A payer engaging non-resident performers through an agency had recorded each fee after the agency's commission, so the slips reported less than the performers had been paid for their services in Canada. We worked back from the engagement contracts and the agency statements to the gross fees, corrected the slips, and reconciled the summary to the remittances on the corrected figures. The engagement produced a restated set of slips and a written basis for the gross-up, which the agency now works to as well.
Read how this one runsSlips filed but the summary had never been prepared
A payer in its first year of engaging non-resident contractors issued slips and stopped there, unaware that a reconciling summary was also due. We prepared it from the payment records rather than from the slip totals, which surfaced one payment that had been reported twice, and filed the summary on the corrected position. The result was a completed year and a short checklist the finance team now follows, listing the records that have to be in hand before the summary can be built.
Read how this one runsRecords enquiry answered by the reconciliation itself
A payer was asked to explain how the amounts it had reported for non-resident contractors related to what it had remitted during the year. The summary was the document that answered, but it had been prepared from totals and could not be traced back to individual payments. We rebuilt the reconciliation payment by payment, identified the items that genuinely differed and why, and provided a schedule running from each payment through to the slip and the remittance. The enquiry closed on that schedule.
Read how this one runsTreaty Rate Refused Because the Paperwork Was Missing
A reduced rate under a treaty is available only where the payer is satisfied the recipient is resident in the treaty country. The certificate and the withholding form are what make the rate available at source instead of recoverable a year later.
Read how this one runsA Non-Resident Estate Holding US Assets
US situs assets sit inside the US estate tax net regardless of where the owner lived, and the exemption available to a non-resident is not the resident one. The file establishes situs asset by asset before any relief is claimed.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
Strategy and compliance for income, assets and families spread across borders.
Industries & Client Types We Serve Worldwide
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
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
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
Form T4A-NR summary — the questions that follow
It changes the work rather than the obligation. The summary ties the payer's records to what the CRA received, and where a waiver was granted mid-year it is the place the pre-waiver and post-waiver periods have to agree. In practice that means splitting the year at the date the waiver took effect, checking that what was withheld and remitted before it matches the slips for that period, and that nothing was withheld after it that should not have been. Reconcile the two periods separately and then total them. Reconciling the year as a single block is how mid-year waiver errors stay hidden.
The payer. The obligation sits with the Canadian business that issued the slips, whoever keys in the figures. A provider preparing the summary is doing the payer's filing, and an error in it is the payer's error. The practical implication is about records rather than blame. The provider usually holds the remittance history, while the payer holds the contracts and the travel evidence that decide which payments were for services performed in Canada. The summary can only reconcile if both sides of that are brought together before it is filed, so agree who supplies what well before the deadline.
Find the difference before you file, because the summary is where it will show. Common causes are a payment converted to Canadian dollars at a different date in the ledger than in the remittance, a fee recorded net of an agent's commission or of reimbursed travel, a payment to a supplier who was not in fact a non-resident, and a remittance posted to the wrong period. Work from the payments outwards rather than from the totals inwards. Identified and explained, a difference becomes a reconciling item you can support. Squeezed into the totals, it becomes an enquiry later.
Think of them as one package rather than two independent filings. The slips report what each non-resident was paid. The summary reconciles those slips to the amounts remitted for the year. Because the summary is built from the same records as the slips, it should be prepared alongside them, and its totals should agree with them line for line before anything is submitted. Preparing the summary last, from the slip totals rather than from the underlying payments, is what produces a set of slips and a summary that do not tell the same story.
Follow the remittances. The summary's job is to reconcile the slips issued to the amounts remitted, so it works at the level of the account the remittances were actually made under. Where two accounts were used during a year, after a reorganisation, an amalgamation, or simply because a second account was opened in error, each has to reconcile on its own, and slips need to be allocated to the account their related remittances went to. Sorting out which account each payment belonged to is usually the bulk of the work, and it is better done before filing than in answer to a query.
It depends on the country, and a day count is only ever the start. Many use a threshold in a tax year, some also look at averages across several years, and some have no day test at all and decide on where your home and life are. Two countries can both conclude you are resident, which is what the treaty tie-breaker exists to settle. Counting days without checking the tie-breaker is how people end up filing as resident nowhere. See the residency tie-breaker.
Cross-border tax is what applies when income, assets or people touch more than one tax system at once — someone living in one country and earning in another, a company selling or hiring abroad, a family holding property in a second country. The work is rarely one country's rules applied harder; it is reconciling two sets of rules and claiming the relief that stops the same income being taxed twice at full rates. See what we do.



