In 2013-0512921E5, the CRA said that 25% withholding tax (WHT) applied to a cross-border “franchise relicensing fee” under s. 212(1)(d).  Subject to specific inclusions and exceptions, s. 212(1)(d) applies generally to any “rent, royalty or similar payment” paid to a non-resident.  This phrase describes a payment made to an owner of property for the right to use such property for a given period of time. The franchise relicensing fee here was captured by this legal description.  The CRA did not discuss a possible reduction of the 25% WHT under any applicable tax treaty.