It has been announced by the OECD that the Budget for 2014 includes the announcement of a consultation on international tax planning by multinational enterprises as input into Canada’s participation in the action plan on the basis of erosion and profit shifting (BEPS). A consultation on tax treaty shopping was also announced. The Budget measures for 2014 contains an extension of the thin capitalization rules to cover back to back loan arrangements where an intermediary is imposed between the Canadian resident and foreign related parties.
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