The Tax Management Transfer Pricing Report ™ provides news and analysis on U.S. and international governments’ tax policies regarding intercompany transfer pricing.
June 29 — Canada's finance minister released proposed legislative changes to implement commitments to the OECD's anti-tax base erosion and profit shifting initiative, and other changes announced in the fiscal 2016-17 budget.
The draft amendments to the Income Tax Act would strengthen Canada's transfer pricing rules by adopting country-by-country reporting, effective for the 2015 taxation year, the Department of Finance said in a July 29 statement.
Measures to adopt BEPS commitments are part of a broad range of legislative and regulatory changes proposed to implement commitments in the Canadian government's budget for fiscal 2016-2017, introduced in the Canadian Parliament March 22 (24 Transfer Pricing Report 1478, 3/31/16).
The amendments would also incorporate penalties for failing to meet the OECD's common reporting standard, under which Canada is to make its first information exchanges in 2018 on financial accounts held in Canada by foreign residents.
The department noted that the proposals have been modified in some cases to take into account consultations since then, but didn't identify specific changes that have been made.
Other international issues addressed in the draft amendments include:
Domestic tax integrity issues covered by the draft amendments would:
The amendments would also expand tax support for clean energy production, including through enhanced capital cost allowance treatment of investments in electric vehicle charging stations and storage equipment for electricity from renewable sources.
The draft amendments to the Income Tax Act and the Income Tax Regulations are open to public comment through Sept. 27.
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The draft proposals are at http://src.bna.com/hg5.
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