According to subsection 233.8(6) of the Act, the Country-by Country (CbC) report must generally be submitted with the CRA no later than 12 months after the last day of the fiscal year to which the report relates. That means, a CbC report for the fiscal year ended December 31, 2016, must be filed with the CRA no later than December 31, 2017.
However, if notification of systemic failure has been received by the constituent entity (CE) of a multinational enterprise (MNE) groups, this deadline can be extended to 30 days after receipt of the notification. This takes into account situations where a CE has been informed of a systemic failure beyond the period within which it could meet the 12 month deadline.
