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Part XIV  ·  Section 219  ·  Schedule 20

Canadian Branch Profits Tax Calculator

A foreign corporation operating through a Canadian branch pays regular income tax and then a second tax on the profits it takes out. Work out the Part XIV liability, the allowance for reinvesting in Canada, the treaty exemption still available, and the total effective rate on branch profits.

Branch tax payable
Reinvestment allowance
Treaty exemption remaining
Total effective rate

Step 1 — Branch Income and Tax Paid

Income earned in Canada for the year


Including the additional tax on branch income


Provincial tax on the same income

Step 2 — Reinvestment in Canada

This year, the allowance that defers the tax


Prior years, recaptured if investment falls


Pulling capital out brings the tax forward

Step 3 — Treaty Position

United States

United States
United Kingdom
Other treaty country
No treaty with Canada

Decides both the rate and the exemption


Please confirm the figure in your treaty


Cumulative across all prior years


Per cent, please confirm the article


Branch tax is reported on Schedule 20

Show the subsidiary comparison

Show the subsidiary comparison
Branch only

A subsidiary pays dividend withholding instead

Part XIV Branch Tax
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branch tax for the year

After-Tax Branch Profit

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Amount Subject to Branch Tax

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Branch Tax Payable

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Exemption Remaining

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Building the Branch Tax Base

LineBasisAmount

The Treaty Position

ItemBasisAmount

Total Canadian Tax on the Branch

ItemBranchCanadian Subsidiary

Points That Decide This

    What to Do Next

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    Disclaimer: Part XIV of the Income Tax Act imposes an additional tax, commonly called the branch profits tax, on a non-resident corporation carrying on business in Canada. Section 219 charges the tax at 25% on the corporation’s amount taxable earned in Canada for the year, which is broadly its after-tax Canadian branch profits reduced by an allowance for any increase in its investment in property in Canada and increased where that investment decreases, so that profits reinvested in the Canadian business are deferred rather than exempted. The tax is intended to approximate the withholding tax that would have applied had the Canadian operations been carried on through a subsidiary paying dividends to its parent. Most of Canada’s tax treaties reduce the 25% rate; the Canada-United States treaty generally reduces it to 5% and provides an exemption for the first CAD 500,000, cumulative over the life of the branch, of the earnings that would otherwise be subject to the tax, reduced by amounts previously exempted. Other treaties differ in both rate and whether an equivalent exemption exists, so the applicable article must be confirmed for the specific country. The branch tax is computed on Schedule 20 and filed with the T2 return. The exemption amount, the treaty rate and the mechanics of the allowance for investment in Canadian property should all be confirmed against the current legislation and the relevant treaty before being relied on; the figures used here are defaults. Whether a foreign corporation is carrying on business in Canada, and whether it has a permanent establishment under a treaty, are separate questions that determine whether any Canadian tax arises at all. This page is general information, not tax advice.

    Why There Is a Second Tax at All

    A foreign company can serve the Canadian market two ways: through a Canadian subsidiary, or through a branch of the foreign company itself. Those two routes would produce very different tax outcomes if nothing corrected for it.

    A subsidiary pays Canadian corporate tax on its profits and then withholding tax when it pays a dividend to its parent. A branch pays Canadian corporate tax and then, without more, could repatriate everything free of further Canadian tax, because a branch does not pay dividends to itself.

    Part XIV is that correction. The branch profits tax approximates the dividend withholding a subsidiary would have paid, so the choice between branch and subsidiary is made for commercial reasons rather than because one of them escapes a layer of tax.

    This is a second tax, not a higher rate. The branch first pays ordinary federal and Ontario corporate tax on its Canadian income. The Part XIV tax then applies to what is left. Reading the treaty rate as the whole Canadian cost understates it considerably.

    Reinvestment Defers the Tax

    The base is not simply after-tax profit. It is after-tax profit reduced by the increase in the corporation’s investment in property in Canada during the year. Profits ploughed back into the Canadian business are not taxed now.

    The deferral is not forgiveness. Where the investment in Canadian property later decreases, the allowance previously claimed comes back into the base and the tax arrives then. A branch that builds up Canadian assets for a decade and then repatriates the accumulated capital faces the deferred tax at that point.

    What the Branch Does With Its ProfitPart XIV Effect
    Reinvests in Canadian propertyAllowance reduces the base, tax deferred
    Repatriates to head officeTaxed this year
    Holds cash in CanadaDepends on whether it counts as qualifying property
    Reduces its Canadian investmentPreviously deferred amounts come back into the base

    The allowance is a running balance, not an annual reset. Cumulative amounts claimed in earlier years sit waiting, and a reduction in Canadian investment pulls them into income. A branch winding down often faces its largest branch tax bill in its final years, precisely when the owner expected the Canadian tax to be finishing.

    The Treaty Does Two Things

    The statutory rate is twenty-five per cent. For a US corporation the treaty generally cuts it to five and, separately, exempts the first five hundred thousand dollars of earnings that would otherwise be caught, cumulative over the life of the branch rather than annual.

    Those two reliefs work together and the exemption is used up once. A branch that shelters four hundred thousand this year has a hundred thousand left for every future year combined, and once it is gone the five per cent applies to everything.

    Track the cumulative exemption from the first year. It is the single figure most often lost when advisers change, and reconstructing it years later from incomplete records is difficult. It belongs in a permanent file alongside the Schedule 20 history.

    Branch or Subsidiary

    Because Part XIV exists to equalise the two, the tax comparison between a branch and a subsidiary is usually closer than people expect. What actually separates them is everything else.

    ConsiderationBranchSubsidiary
    Early-year lossesOften usable against foreign incomeTrapped in Canada
    Liability exposureSits with the foreign companyContained in the subsidiary
    Second layer of Canadian taxPart XIV branch taxDividend withholding
    Administrative burdenNo separate company to maintainSeparate filings and governance
    Financial disclosureHead office figures can be drawn inContained
    Converting laterPossible, with tax consequencesPossible, with tax consequences

    The common pattern is a branch in the loss-making early years, when the losses are useful at home, followed by incorporation once the Canadian operation turns profitable. That conversion is itself a taxable event and needs planning rather than an assumption that it can be done at will.

    Whether There Is a Branch at All

    All of this assumes the foreign corporation is carrying on business in Canada and, under a treaty, has a permanent establishment here. Neither is automatic, and a company with Canadian customers, a warehouse or a visiting salesperson may or may not cross those lines.

    Where there is no permanent establishment, a treaty generally prevents Canada from taxing the business profits at all, and the branch tax question never arises. That threshold is worth settling before computing anything on this page.

    What This Calculator Does Not Cover

    • Whether a permanent establishment exists, which decides whether Canada can tax the profits at all
    • The detailed composition of qualifying Canadian property for the investment allowance
    • Allocation of head office expenses to the Canadian branch, which is frequently contested
    • Thin capitalisation and interest deductibility on funding from head office
    • Converting a branch to a subsidiary and the tax consequences of doing so
    • Foreign tax credit relief in the home country for the Canadian tax paid

    If the branch has been running for several years without Schedule 20 being tracked properly, that is worth reconstructing now. Our non-resident corporation service covers the branch tax computation, the cumulative allowance, the treaty exemption history and the branch-versus-subsidiary decision.

    Frequently Asked Questions

    Common questions on Canadian branch operations of foreign corporations.

    What is the branch profits tax in Canada?
    An additional tax under Part XIV charged at 25% on a non-resident corporation’s after-tax Canadian branch profits, reduced by an allowance for increases in its investment in Canadian property. It exists to approximate the dividend withholding a Canadian subsidiary would have paid, so that branch and subsidiary structures bear a comparable Canadian tax burden.

    What is the branch tax rate for a US corporation?
    The Canada-United States treaty generally reduces the 25% statutory rate to 5%, and separately exempts the first CAD 500,000 of earnings that would otherwise be subject to the tax, cumulative over the life of the branch. Please confirm both against the current treaty text for your circumstances.

    Is the $500,000 exemption annual?
    No. It is cumulative over the life of the branch, reduced by amounts exempted in earlier years. A branch that uses four hundred thousand of it in one year has one hundred thousand remaining for all future years combined, after which the treaty rate applies to everything.

    How does reinvesting in Canada reduce the branch tax?
    The base is after-tax profit less the increase in the corporation’s investment in Canadian property for the year, so profits ploughed back into the Canadian business are not taxed now. It is a deferral rather than an exemption: if the Canadian investment later decreases, previously allowed amounts come back into the base.

    Is a branch or a Canadian subsidiary better?
    On tax alone they are closer than people expect, because Part XIV exists precisely to equalise them. The real differences are elsewhere: early losses are often usable at home through a branch but trapped in Canada in a subsidiary, while a subsidiary contains liability and limits financial disclosure.

    Where is the branch tax reported?
    On Schedule 20, filed with the T2 corporate return. The cumulative allowance for investment in Canadian property and the cumulative treaty exemption used both need tracking across years, and reconstructing them later from incomplete records is one of the harder pieces of remedial work on a branch file.

    Do I pay branch tax if the branch makes a loss?
    No. With no after-tax profit there is nothing in the base. The loss years are often exactly why a branch was chosen over a subsidiary, since the losses may be usable against the foreign corporation’s other income rather than trapped in a Canadian company.

    Can I convert the branch into a Canadian subsidiary later?
    Yes, and it is a common sequence once the Canadian operation turns profitable. It is a taxable event with its own consequences, including the treatment of the accumulated investment allowance, so it needs planning rather than being assumed available on demand.

    Track the Cumulative Figures Before They Are Lost

    Send us the branch financial statements, the Schedule 20 history and the treaty exemption used to date. We will compute the branch tax properly, rebuild the cumulative allowance if it has drifted, and price the branch against a Canadian subsidiary.

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