Regulation 105 Waiver / Reduction (R105) – Treaty-Based & Hardship
What it covers Eligibility review (treaty position / PE / scope of work) Prepare and file the R105 waiver/reduction package Support through CRA follow-ups
Key services
Eligibility & Treaty Review (treaty position, permanent establishment, scope of work)
R105 Waiver/Reduction Application (prepare and file the waiver request)
CRA Follow-Up & Case Management (handle questions, updates, and support through approval)
Why choose us
Years of experience
No hidden fees
Great results
Regulation 105 Waiver / Reduction (R105) – Treaty-Based & Hardship
At Larivco & Cie, we help non-resident companies reduce or eliminate the 15% Regulation 105 withholding when it’s not aligned with the tax that should ultimately be owed. If you’re providing services in Canada and your Canadian customer is required to withhold 15%, a Reg 105 waiver or reduction (R105) can be a key cash-flow solution—when eligibility is properly supported.
Fast clarity on eligibility (treaty + facts)
Not every engagement qualifies. We start with a focused eligibility review to determine whether a waiver or reduction is realistic based on:
your tax treaty position
whether you may have a Permanent Establishment (PE) in Canada
the scope of work, where the services are performed, who performs them and for how long
This upfront review avoids wasted filings and ensures your strategy is defensible.
A complete R105 package that CRA can approve
Canada Revenue Agency (CRA) decisions depend on the quality of the submission. We prepare and file a full R105 waiver/reduction package that is clear, consistent, and aligned with your engagement facts. The goal is simple: present a clean, well-documented request that supports reduced withholding and protects your cash flow.
End-to-end support through CRA follow-ups
Waiver files often require follow-up questions, clarifications, or additional documents. We manage the process from start to finish—tracking timelines, responding to CRA requests, and keeping both the non-resident service provider and the Canadian payer aligned so payments can proceed with the right withholding treatment.
Built for cross-border service providers
We regularly support companies from the US, UK, France, and Germany delivering project-based services in Canada across all industries (IT, engineering, professional services, construction, and more). Our approach is direct, practical, and designed to reduce friction with Canadian customers’ AP/Finance teams.
Common related needs: Regulation 105 compliance setup for Canadian payers, subcontractor reimbursement relief, and CRA audit support.