New Notice of Ways and Means Motion to Implement Tax Measures in Economic Action Plan 2014

Par Robert Robillard - 16 octobre 2014

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Department of Finance Canada recently released its latest Notice of Ways and Means Motion. Regarding international taxation, it includes:

  • « Better circumscribing an existing exception from the « investment business » definition in the foreign accrual property income regime by introducing additional conditions for the application of the exception [Section 94, 94.2].
  • Adjusting Canada’s foreign accrual property income rules in order to address offshore insurance swap transactions and ensure that income derived directly or indirectly from the insurance of Canadian risks is taxed appropriately [Section 95].
  • Addressing back-to-back loan arrangements involving an intermediary by adding a specific anti-avoidance rule in respect of withholding tax on interest payments, and modifying an existing anti-avoidance rule in the thin capitalization rules [Subsections 18(6)/(6.1), 212(3.1)/(3.2)/(3.3)]. »

The full NWMM is available here.

Robert Robillard, CPA, CGA, MBA, M.Sc. Econ.
Transfer Pricing Chief Economist, RBRT Inc.
514-742-8086; robert.robillard « at » localhost

RBRT Inc. is all about transfer pricing. We specialize in transfer pricing. Our services include transfer pricing documentation, transfer pricing dispute resolution, advanced pricing agreement (APA), value chain management and TP planning, transfer pricing training. The information in this blog post is general information only. Data and information come from sources believed to be reliable but complete accuracy cannot be guaranteed. RBRT Inc. and the author are not responsible or liable for any error, omission or inaccuracy in such information. Readers should seek independent tax advice and tax counsel from RBRT Inc. as required.