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.
DRTP Consulting Inc. solutions go beyond transfer pricing and international tax solutions. This blog post originally appeared at rbrt.ca. 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. DRTP Consulting Inc. or the author are not responsible or liable for any error, omission or inaccuracy in such information. Readers should seek advice and counsel from DRTP Consulting Inc. as required.
- Posted by Robert Robillard
- On 16 October 2014
- 0 Comments
- Canada Revenue Agency, Notice of Ways and Means Motion, Transfer Pricing Canada