The new Liberal government's first budget included a number
of cross-border measures impacting transfer pricing documentation,
the arm's length principle for transfer pricing, the
back-to-back loan anti-avoidance rules, and the cross border
anti-surplus stripping rules.
Canada to legislate country-by-country reporting
The budget signalled the government's intention to
strengthen transfer pricing documentation by legislating
country-by-country reporting requirements for large
multinationals.
For taxation years beginning after 2015, Canadian headquartered
multinationals or Canadian subsidiaries of foreign multinationals
with total annual consolidated group revenues of €750 million
or more will be required to file a country-by-country report with
the Canada Revenue Agency (CRA) within one year of the end of the
fiscal year to which it relates. The country-by-country report will
provide a high-level overview of the global operations of large
multinationals including
