The deadline for filing certain country-by-country (CbC) reports generally is 31 December 2017 for multinational enterprise (MNE) groups with a 31 December 2016 fiscal year-end.
In some instances, Canada (as well as other tax jurisdictions) may require domestic entities to file a CbC report for the MNE group when there is no exchange relationship in effect—even if the MNE has filed its report in another jurisdiction. In addition, certain MNEs may need to file a Canadian CbC report, even if the parent entity files a CbC report in another jurisdiction.
Although Canada has a number of exchange agreements with various jurisdictions, some of these exchange agreements will only be entering into force for tax periods starting on or after 1 January 2017—and therefore would not be effective for the 31 December 2016 fiscal year-end. Therefore, constituent entities of MNEs that file CbC reports in these jurisdictions may still have an obligation to file a Canadian CbC report.
Read a December 2017 report prepared by the KPMG member firm in Canada
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