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...

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No secondary reporting in Canada if NR UPE exceeded the threshold in local currency

The impact of currency fluctuations on the €750 million...

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CbCR exchanges only with jurisdictions respecting confidentiality

Confidentiality of CbCR reporting information

…Canada will automatically...

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CbCR data not used directly in assessing

Appropriate use of CbCR reporting information

The BEPS Action 13 Final Report sets out three permitted...

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Presumption of gross negligence after 2017 filing year

Paragraphs 162(10)(a) and (b) of the Act

The penalty under subsection 162(10) of the Act...

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Private Holdco can be a UPE

Non-publicly traded UPEs

There may be situations where one or more individuals ultimately own non-publicly traded...

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Canadian constituent entity (CE) cannot be surrogate parent entity (SPE) of Canadian ultimate parent entity (UPE)

Reporting Entity

The reporting...

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