Canada: CRA releases new circular on advance pricing arrangements (APAs)

March 09, 2024

On 22 February 2024, the Canada Revenue Agency (CRA) released the Information Circular 94-4R2 on International Transfer Pricing: Advance Pricing Arrangements (APAs). This circular offers detailed guidance on APAs, focusing on the prerequisites for

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Canada mulls tax credits for clean hydrogen and tech manufacturing 

December 23, 2023

On 20 December 2023, Canada's Department of Finance launched consultations on introducing tax credits for clean hydrogen investment and Clean Technology Manufacturing investment. As detailed in the 2023 Fall Economic Statement, the government is

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Canada announces legislation to implement digital services tax

November 30, 2023

On 28 November 2023, Ms. Chrystia Freeland, Deputy Prime Minister and Minister of Finance, tabled the Notice of Ways and Means Motion to introduce the Fall Economic Statement Implementation Act, 2023. This legislation, which delivers on key

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Canada updates electronic filing requirements for business entities

August 20, 2023

On 16 August 2023, the Canada Revenue Agency (CRA) announced that businesses filing six or more information returns must file them electronically to avoid penalties. Recent legislation has amended mandatory electronic filing thresholds.

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Canada releases revised draft DST Act for public comments

August 19, 2023

On 4 August 2023, the Department of Finance Canada published a revised draft of the Digital Services Tax (DST) Act for public consultation. These legislative proposals would implement the Digital Services Tax Act. The Act would impose a tax

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Canada releases draft Global Minimum Tax Act for public comments

August 15, 2023

On 4 August 2023, Canada issued draft legislation aimed at implementing the "Pillar Two" global minimum tax framework established by the Organisation for Economic Co-operation and Development (OECD) and the G-20 Inclusive Framework on Base Erosion

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Canada plans to enact DST in 2024

July 14, 2023

On 12 July 2023, Canadian Deputy Prime Minister and Minister of Finance said “two years ago, we agreed to pause the implementation of our own Digital Services Tax (DST), in order to give time and space for negotiations on Pillar One. But we were

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Canada releases consultation paper on reforming transfer pricing rules

June 15, 2023

On 6 June 2023, the Canadian Department of Finance issued a consultation paper on reforming and enhancing Transfer Pricing Rules. Budget 2021 announced the government’s intention to consult on Canada’s transfer pricing rules with a view of

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Canada: Tax measures in federal budget 2023

April 15, 2023

On 28 March 2023, Ms. Chrystia Freeland, the Deputy Prime Minister and Minister of Finance released Budget 2023. Canada’s economic growth was the strongest in the G7 over the last year, and today, 830,000 more Canadians are employed than before

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Canada releases Fall Economic Statement Implementation Act 2022

December 23, 2022

On 15 December 2022, Bill C-32, the Fall Economic Statement Implementation Act 2022, received Royal Assent in Canada. Key measures adopted in Bill C-32 to make life more affordable include: Permanently eliminating interest on Canada Student

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Canada: Consultation on Strengthening the General Anti-Avoidance Rule

August 11, 2022

On 9 August 2022 the Canadian government published a consultation paper on strengthening the general anti-avoidance rule (GAAR). Comments are invited by 30 September 2022. The paper notes that the GAAR, which was first introduced in 1988, has

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Canada enacts Budget for 2022

July 10, 2022

Canada has published the Budget Implementation Act, 2022, No. 1, which received royal assent on 23 June 2022 and provides for the implementation of certain measures proposed as part of the Budget 2022. Key measures in Budget Bill C-19 include:

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Canada enacts federal budget bill 2022

June 28, 2022

On 23 June 2022, Canada's Budget Implementation Act 2022, No. 1, Bill C-19 which includes several tax measures received Royal Assent. Bill C-19 implements tax measures announced in the 2022 and 2021 federal budgets, as well as various other

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Canada: Government invites feedbacks on draft legislation regarding hybrid mismatches

May 10, 2022

On 29 April 2022, the Finance Department published a draft legislation proposals that would address hybrid mismatch arrangements, which are used primarily by multinational enterprises to avoid paying their fair share of tax, as committed to in

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Canada: Bill-19 receives its first reading to implement some measures of Budget 2022

May 06, 2022

On 28 April 2022, Bill C-19, introduced by the Deputy Prime Minister and Minister of Finance, was received its first reading for implementing some measures of Budget 2022. Some highlighting points are given below: Government banned foreign

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Canada: Finance Ministry presents Budget 2022

April 15, 2022

On 7 April 2022, the Finance Ministry presented Budget 2022. Some of the tax measures for business in the Budget are given below: Small business tax rate According to the Budget, qualifying businesses benefit from the small business 9%

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Canada: Finance Department invites public comments on draft tax proposals

March 18, 2022

On 4 February 2022, the Canadian federal government released draft legislation to implement a variety of proposed tax measures including the new "Excessive Interest and Financing Expenses Limitation" (EIFE Limit) first announced in the April 2021

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Canada: Public comments of draft tax Proposals for Certain Budget 2021

February 15, 2022

On 7 February 2022, the Department of Finance released for public comment a set of draft legislative proposals to implement previously announced and other tax measures. Specifically, the proposals would implement Budget 2021 measures to: Allow

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