Manager

Herbalife Canada Ltd.

113-7075 Place Robert-Joncas

Nov 17, 2022

Dear Distributor,

Re: Canadian Income Tax Withholding Rules

We are writing in regard to Canadian income tax rules that apply to your paid earnings as a non-resident of
Canada, in respect of the sales by Distributors in your organization, made in Canada.
Regulation 105 of the Income Tax Act (Canada) requires that every person paying to a non-resident of Canada
a “fee, commission or other amount in respect of services rendered in Canada, of any nature whatever” must
withhold 15% of such payment. It is our understanding that if Herbalife Canada makes a payment to a non-
resident that generally relates to services that are “rendered in Canada,” Herbalife Canada will be required to
withhold 15% of the payment and remit it to the Canada Revenue Agency in respect of the non-resident
person’s possible Canadian income tax liability. Such withholding and reporting is required even if the non-
resident is exempt from Canadian tax under a bilateral tax treaty binding on Canada.
For a service to be “rendered in Canada,” it is our understanding that the Canada Revenue Agency’s general
approach is that services are rendered at the place where the service provider is located at the time at which
such service is rendered or performed, so that withholding and reporting would not be required if the person
providing the services is outside Canada at the time any services are performed. Accordingly, it is our
understanding that this means for Distributors who are not residents of Canada and who do not enter Canada to
perform services, no Regulation 105 withholding is required.
In order to ensure that Herbalife complies with Canadian tax laws, Herbalife Canada requires that you review,
complete and return to us the attached Declaration. The Declaration indicates whether you will or will not be
entering Canada in connection with your Herbalife business during the 2023 calendar year such that you could
earn Canadian service income, and whether withholding will or will not be required for Canadian tax purposes.
Deadline for mailing back or emailing back the Declaration to the Montreal Address above is December
31, 2022. Once we have received your signed Declaration, Herbalife Canada will proceed as appropriate.
Please note that this Declaration is only for the 2023 calendar year and new Declaration will be requested for
subsequent calendar years. If your activities change at any time during the year after you have submitted your
Declaration, you are required to notify Herbalife Canada so your situation can be reviewed. If Herbalife
discovers that you performed services in Canada during the calendar year, Herbalife Canada will be required to
withhold 15% of your related payments regardless of whether Herbalife received a signed Declaration.
Please also note that regardless of qualification for exemption and the completion of the attached Declaration,
you may be required to file an income tax return in Canada. Members are solely responsible for the proper
reporting of their income and the payment of their taxes. You may wish to contact your tax advisor if you
have any questions regarding your Canadian tax situation.
If we can be of any further assistance, please feel free to contact your local Distributor Services department or
email to Member services at Canrecords@Herbalife.com

Yours truly,

Distributor Services
 Manager
Herbalife Canada Ltd.
Arturo Gomez

113-7075 Place Robert-Joncas

Herbalife Nutrition Canada

DECLARATION for year 2023

Narasimha r
I, ____________________________________, declare that:
(Distributor Name (Print) and Member Herbalife ID number)

1. India
I am a Herbalife Distributor and am currently a resident of ____________________.
(Country)

2. I am not a resident of Canada and will not be a resident of Canada for Canadian tax
purposes during the 2023 calendar year. I do not normally or ordinarily live in Canada and
do not spend more than 182 days in Canada in any 12-month period.

3. I neither have, nor am I deemed to have, a permanent establishment or fixed place of

Please select one of the following by checking the appropriate statement:

____ I WILL enter Canada in the 2023 calendar year for the purpose of rendering any services in
Canada to Herbalife Canada or any other Herbalife Distributor in respect of payments I receive from
Herbalife Canada. As a result 15% income tax will be withheld per Regulation 105 of Canadian
Income Tax Act.

___ I WILL NOT enter Canada in the 2023 calendar year for the purpose of rendering any services
in Canada to Herbalife Canada or any other Herbalife Distributor in respect of payments I receive
from Herbalife Canada. I WILL immediately notify Herbalife Canada in writing if I begin rendering
such services in Canada at any time during the calendar year.

I declare under penalty of perjury that the forgoing is true and correct.

Executed this 30th day of December , 20 22 ,

Bangalore , Karnataka
at_________________________________________, India
____________________________.
(City and Province) (Country)

Narasimha R W2901950
Distributor’s Name (Print) and Herbalife ID Number
Narasimha R Digitally signed by Narasimha R
Date: 2022.12.30 16:42:14 +05'30'
________________________________
Distributor’s Signature