Section 233.8

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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 90

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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),...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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 121

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.