On April 19, 2021, the Federal Minister of Finance, Chrystia
Freeland, presented the Liberal government's first Budget in
over two years.
One of the over-arching tax themes of Budget 2021 was the
continuing pursuit of the recommendations made by the Organisation
for Economic Co-operation and Development (the
"OECD") in connection with its
"Base Erosion and Profit Shifting" Project (the
"BEPS Project").
In 2015, as part of the BEPS Project, 15 separate action items
were released by the OECD that were aimed at encouraging the
coordinated reform of international tax rules. Since 2015, the
Canadian government has sought to implement several of the proposed
action items.
In Budget 2021, the government proposes to introduce measures to
address perceived tax inequities that flow from certain
"hybrid mismatch arrangements" identified as part of the
BEPS Project. The government has expressed concern that
multinational enterprises may take advantage of foreign
