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ARTICLE · 05 JULY 2019

Canada Close To Ratifying The Multilateral Instrument

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Bill C-82, An Act to implement a multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting, has received royal assent.

CanadaTax
Gwen Watson
Gwen Watson
Andrew Wong
Andrew Wong
Richard Johnson
Richard Johnson
Judah (Ari) Feder
Judah (Ari) Feder
Joshua Morry
Joshua Morry
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Bill C-82, An Act to implement a multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting, has received royal assent. The federal government is now one step closer to completing the ratification process that will bring into force for Canada the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).

What you need to know

  • Canada is currently one of 88 countries that has signed the MLI. It is expected over 80 of Canada's tax treaties will be modified by the MLI.
  • The MLI will modify the majority of Canada's bilateral tax treaties to incorporate certain anti-avoidance countermeasures, including a principal purpose test (PPT). This could impact the ability of taxpayers to access treaty benefits, such as relief in respect of withholding taxes and taxes on capital gains.

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