Canada CRA publishes a notice regarding the effect of MFN provisions with Lithuania
Recently, the Canada Revenue Agency (CRA) has published a Notice regarding the impact on the Most Favoured Nation (MFN) provision of the Canada–Lithuania Income Tax Convention with respect to certain royalties. Effective January 1, 2019, the
See MoreCanada: CRA publishes a notice regarding the effect of MFN provisions with Latvia
Recently, the Canada Revenue Agency (CRA) has published a Notice regarding the impact on Most Favoured Nation (MFN) provision of the Canada–Latvia Income Tax Convention with respect to certain royalties. Effective January 1, 2018, the
See MoreCanada: The Budget implementation Bill 2021 receives Royal Assent
On 29 June 2021, the 2021 Budget Implementation Act (“Bill C-30”) received Royal Assent, which includes certain tax measures that were proposed in the 2021 Federal Budget, the 2020 Fall Economic Statement, and the 2019 Federal Budget. Bill
See MoreCanada: CRA replaces and abolishes a Circular regarding MAP
On 1 June 2021, the Canada Revenue Agency (CRA) published Information Circular IC71-17R6, which replaces and cancels Information Circular 71-17R5 dated January 1, 2005. This Circular describes several changes related to MAP. MAP filing
See MoreCanada: Finance Minister presents Budget 2021
On 19 April 2021, the Finance Minister, Chrystia Freeland, presented Budget 2021, which includes important business tax measures, digital service taxes, limitation of interest deduction, hybrid mismatch arrangements, transfer price cases, mandatory
See MoreCanadian mining company wants to resolve its tax dispute with NAFTA arbitration
On 2 March 2021, a publicly traded Canadian mining company (First Majestic Silver), has resorted to international arbitration to resolve an ongoing transfer pricing dispute with the Mexican government over tax reassessments the government made in
See MoreCanada: CRA announces not to pay cost recovery charge for APAs
On 5 February 2021, the Canada Revenue Agency (CRA) announced that they will no longer require taxpayers to provide a cost recovery charge when entering the Advance Pricing Arrangement (APA) program. Previously, the charge was used to cover the
See MoreCanada: Finance Department introduces new GST/HST requirement for new DST
On 30 November 2020, the Finance Department published the Fall Economic Statement 2020 - Supporting Canadians and Fighting COVID-19, including prudent fiscal plan with proposed measures for a tax system for the digital economy. Under current rules,
See MoreCanada: The Tax Court makes a decision in a case regarding transfer pricing dispute
On 27 August 2020, the Tax Court of Canada made a decision in a case, Canada vs AgraCity Ltd. and Saskatchewan Ltd., in favor of Candian company AgraCity Ltd. and related company, Saskatchewan Ltd. The AgraCity Canada had entered into a Services
See MoreCanada: CRA further extends the application periods regarding international tax issues
On 31 August 2020, the Canadian Revenue Agency published a Guidance in their website to announce further extension of the application period until 30 September 2020 on various international tax issues arising due to COVID-19. This Guide includes
See MoreCanada: CRA extends payment deadline of income tax return
On 27 July 2020, the Canada Revenue Agency (CRA) announced that payment deadline for the year 2020 of the income tax returns, including installments for legal entities, trust, and individual is to be extended from 1 September 2020 to 30 September
See MoreCanada: Federal Court of Appeal makes a decision in a transfer pricing case
On 26 June 2020, the Federal Court of Appeal made decision in a transfer pricing case, entitled “The Queen v. Cameco Corporation, 2020 FCA 112” in favour of the taxpayer, i.e. Cameco Corporation. The Cameco Corporation, together with its
See MoreCanada: Government confirms the end of GST payment scheme
On 30 June 2020, the Federal Government confirmed the ending of the GST or GST payment delay scheme. However, businesses still in COVID-related difficulties, may apply for continuing payment
See MoreCanada: The CRA extends tax return deadline until 1 September 2020
On 1 June 2020, the Canada Revenue Agency (CRA) published updated information on their website regarding the extension of corporate tax return or information return submission deadline for businesses, trusts, or partnerships until 1 September 2020
See MoreCanada: CRA extends the corporate individual tax return deadline
On 25 May 2020, the Canadian Revenue Authority (CRA) announced new extended deadlines for corporations and trusts in response to COVID-19 pandemic. According to the announcement, the CRA will allow an extension up to 1 September 2020 for
See MoreCanada: Federal Court of Appeal makes a decision on a case regarding GAAR
On 5 May 2020, the Federal Court of Appeal has made a decision on a case entitled, “2018 TCC 187”, which was against the tax authorities, but in favor of the Tax Court of Canada's decision or the taxpayer. The Federal Court finds that the loss
See MoreCanada: CRA announces some tax relief measures during COVID-19 pandemic
The Canada Revenue Agency (CRA) has recently announced few tax relief measures. These includes: On 21 April 2020, the CRA launched general guidance concerning the Canada Emergency Wage Subsidy (CEWS) and a calculator for determining the subsidy
See MoreCanada: The CRA cancels Circular IC 87- 2R regarding guidance for applying TP rules
The Canada Revenue Agency (CRA) has cancelled the Circular IC 87- 2R as from 30 December 2019, because it is inconsistent with the interpretation and application of Canadian transfer pricing legislation and does not reflect updates to the OECD
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