In 2014-0542411R3 (recently released), a Canadian subsidiary in a foreign-controlled group (Canco) entered into a secondment arrangement with a foreign sister company in the group (Forco).  Under this arrangement, Forco was obligated to provide employees to Canco, which would assist Canco in carrying on its business in Canada.  The seconded employees would become employees of Canco, but “for administrative reasons” the employees would continue to be paid by Forco.  All costs relating to the seconded employees' remuneration would be reimbursed by Canco to Forco, with no mark-up (see paragraphs 12 and 13).  The CRA ruled that no withholding would be required under Reg. 105, and that Forco would not be considered to carry on business in Canada through a permanent establishment (see page 11).  Obviously, Reg. 102 (employment) withholdings in Canada would apply to the remuneration paid to the employees.