Regulation 105 imposes a 15% withholding tax (WHT) on any payment made to a non-resident in respect of services rendered in Canada.  In 20140563611E5 (recently released), the CRA said that this WHT generally would not apply to payments made to a non-resident providing services from an established “call centre” outside Canada.  However, the CRA refused to give any comfort with respect to “various office, administrative and support” services provided by the non-resident.