As a general rule, non-resident actors or entertainers who derive income from performing in Canada will be subject to Canadian tax on such income. Typically, such persons are self-employed independent contractors, rather than employees. Therefore, they will be subject to tax in Canada on the basis that they are carrying on a business in Canada [1].

Even if they are resident in a country with which Canada has a tax treaty, they will generally still be subject to Canadian tax on income from such activities in Canada. Typically, Canada’s tax treaties contains a special provision that allows Canada to tax the income of actors and entertainers (as well as athletes), even if there is no “permanent establishment” or “fixed base” in Canada [2]. This will be the case even if the actor or entertainer forms a corporation through which to provide his or her services {3]. Read More