Canada: 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
See MoreCanada: Government extends deadline for filing income tax return and payments
On 18 March 2020, the Prime Minister and the Finance Minister announced some tax relief measures due to COVID-19 outbreak: The federal corporate tax return deadline is extended to 1 June 2020. The filing deadline extensions have also been
See MoreCanada: CRA updates on administrative income tax measures due to COVID-19 pandemic
On 26 March 2020, the Canada Revenue Agency made an announcement that in addition to the income tax filing and payment deadline extensions announced as part of the fiscal measures, both companies and individuals may defer a number of other
See MoreCanada: Prime Minister announces a Plan to provide support for businesses during COVID-19 pandemic
On 13 March 2020, the Finance Minister, Bill Morneau, announced COVID-19 Economic Response Plan to help stabilize the economy and help Canadians affected by the impacts of the COVID-19 pandemic period. To support Canadian businesses during this
See MoreCanada: Reminder for the CbC reporting form submission process
On 9 January 2020, Government announced that as from 1st June 2020, Canadian ultimate parent entities that are corporations must file the RC4649 electronically using EFILE or Web Access Code (WAC). It will be available through CRA-T2-certified
See MoreCanada: BEPS multilateral instrument (MLI) enters into force
On 1 December 2019, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Canada. On 29 August 2019, Canada deposited its ratification instrument for
See MoreCanada: Finance Minister announces Alberta’s 2019 Budget
On 24 October 2019, the Finance Minister of Alberta, presented the 2019 province budget. The budget does not contain any new changes to the corporate or individual income tax rates. It excludes several tax credits, including the scientific research
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