Subsection 233.8(1)
Excluded MNE Group
Administrative Policy
RC4651 “Guidance on Country-By-Country Reporting in Canada” 23 November 2018
No secondary reporting in Canada if NR UPE exceeded the threshold in local currency
The impact of currency fluctuations on the €750 million...
Ultimate Parent Entity
Administrative Policy
RC4651 “Guidance on Country-By-Country Reporting in Canada” 23 November 2018
Private Holdco can be a UPE
Non-publicly traded UPEs
There may be situations where one or more individuals ultimately own non-publicly traded...
Subsection 233.8(3)
Administrative Policy
27 March 2019 CTF Seminar - Transfer Pricing
Canada has committed to the “appropriate use” of CbC reporting, namely, its use in assessing risk in transfer-pricing and other BEPS-related...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(10) | downward-adjustment requests reviewed for whether there is double non-taxation | 115 |
| Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) - Paragraph 247(2)(d) | 3-step process before s. 247(2)(d) is applied | 175 |
| Tax Topics - Income Tax Act - Section 231.1 - Subsection 231.1(1) - Paragraph 231.1(1)(a) | access to tax accrual working papers only where necessary | 110 |
RC4651 “Guidance on Country-By-Country Reporting in Canada” 23 November 2018
Interpretive relevance of BEPS materials
Interpretation of Canadian CbCR legislation
[T]he Canadian CbCR legislation generally conforms to the...
29 November 2016 CTF Roundtable Q. 9, 2016-0669801C6 - BEPS Action Item 13
CRA indicated that BEPS Action Item 13 had been dealt with by the introduction of proposed s. 233.8 (respecting country-by-country reporting),...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(4) | BEPS 13 has no effect on the s. 247 documentation requirements | 119 |
Subsection 233.8(6)
Administrative Policy
RC4651 “Guidance on Country-By-Country Reporting in Canada” 23 November 2018
Canadian constituent entity (CE) cannot be surrogate parent entity (SPE) of Canadian ultimate parent entity (UPE)
Reporting Entity
The reporting...