Canada: Guidance about CbC reporting

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The Canada Revenue Agency (CRA) has released a Guide ‘RC4651 on 2nd March 2017 regarding Country-By-Country Reporting (CbCR) in Canada, which is only available in electronic format. This is a new filing obligation for multinational enterprise (MNE) groups with consolidated revenues of €750m or more. This guide gives information on the interpretation of Canadian CbCR legislation, the effective date of CbCR in Canada, excluded MNE groups, voluntary filings, the secondary reporting mechanism, notifications needed for CbCR reporting, entities required to submit in Canada, deadlines, penalties, automatic exchange of CbCR information, confidentiality of information, etc. The guidance follows the CRA’s recent release of ‘Form RC4649. This form is a prescribed country-by country report that affected MNE groups will be needed to submit for MNE fiscal years starting on or after 1st January 2016. The CRA’s Form RC4649 is based on the OECD’s model CbC report. It needs MNE groups to report their revenues, taxes paid, profits, accumulated earnings, stated capital, number of employees and tangible assets regarding each constituent entity (CE) and aggregated by jurisdiction, as well as the main activities of each CE of the MNE group. This guide provides instructions on the interpretation of Canada’s CbC reporting legislation on various issues like notification necessities, obligations under the secondary filing procedure, the impact of currency fluctuations on the €750m filing threshold, MNE groups that must incorporate on Form RC4649, investment funds rules, penalties, fiscal years less than twelve months, and the automatic exchange of CbC reports between tax administrations.

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