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Add merchandise, say, $25 a head and that’s roughly $5.9 million in gross sales, with perhaps 35 per cent of that, or $2.05 million, flowing back as royalty, thus forcing a 25 per cent withholding tax.

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On that combined $27.45 million, Regulation 105 and the 25 per cent royalty withholding would pull more than $4.3 million before the tour bus leaves the country. That’s a whole lotta Rosie held by the CRA against a final tax bill that, once touring costs are deducted, is almost certainly a fraction of that.

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The recovery requires a T1 or T2 return to be filed under Section 115 of the Income Tax Act, depending on who was paid. The 25 per cent royalty withholding is a different animal: that’s generally a final tax; there’s no return to file to get it back.

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Because 15 per cent of gross revenue almost always exceeds a touring act’s real Canadian tax liability once expenses are counted, the system allows for certain waivers.

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Since 2018, the CRA has offered a simplified process for non-resident artists and athletes earning no more than $15,000 in Canada annually, which is handy for a support act, but useless for AC/DC. Above that threshold, touring artists don’t get the easier path other non-resident service providers can use. Instead, they get thunderstruck.

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Budget 2024 proposed giving the CRA legislative authority to issue a single waiver covering multiple transactions over a specified period, rather than engagement by engagement, which is precisely the high voltage a touring act needs.

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That measure became law through Bill C-15 earlier this year, but the CRA hasn’t yet built the process to use it. Separately, the CRA ran its own consultation through summer 2025 and has said administrative improvements are coming this year.

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Angus Young and his advisers have long figured all of this out. But the mid-tier and emerging acts who don’t have a battalion of tax experts can often get shot down in flames by the compliance complexity. The rules aren’t unreasonable in principle — Canada has every right to tax income earned on its soil — but getting relief from over-withholding is disproportionately burdensome relative to the revenue at stake.

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If Canada wants to be a more attractive stop on a global tour with its related economic benefits, the multi-transaction waiver authority in Bill C-15 is a real step forward. But it will only matter if the CRA implements it with fast turnaround times and clear, published criteria.

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A touring act needs certainty measured in weeks, not months. In other words, the dirty deeds need to be done dirt cheap.

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I’ll be keeping a stiff upper lip at the Vancouver show, trying to forget about Regulation 105 for two hours. Bill C-15 gave the CRA the amplifier. For those about to rock — and those about to withhold — we salute you.

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Kim Moody, FCPA, FCA, TEP, is the founder of Moodys Tax/Moodys Private Client, a former chair of the Canadian Tax Foundation, former chair of the Society of Estate Practitioners (Canada) and has held many other leadership positions in the Canadian tax community. He can be reached at kgcm@kimgcmoody.com and his LinkedIn profile is https://www.linkedin.com/in/kimgcmoody.

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