Canada plans to enact DST in 2024
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
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
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
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
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
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
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
See MoreCanada: Government invites feedbacks on draft legislation regarding hybrid mismatches
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
See MoreCanada: Bill-19 receives its first reading to implement some measures of Budget 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
See MoreCanada: Finance Ministry presents Budget 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%
See MoreCanada: Finance Department invites public comments on draft tax proposals
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
See MoreCanada: Public comments of draft tax Proposals for Certain Budget 2021
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
See MoreCanada 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
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