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Transfer Pricing: Canada Signs Agreement for Exchange of Country-by-Country Reports


​On May 12, 2016, Canada signed the Multilateral Competent Authority agreement for the automatic exchange of Country-by-Country reports (CbC MCAA), bringing the total number of signatories to 39 countries. The CbC MCAA allows all signatories to bilaterally and automatically exchange Country-by-Country (CbC) reports.

The CbC reports are forms that large multinational enterprises (MNE’s) will be required to file with the tax administration of the country in which the ultimate parent entity resides. The form contains a variety of information for each jurisdiction in which the MNE operates, including metrics relating to global allocation of income and taxes, and indicators of the type and location of economic activity within the MNE. The CbC Report is intended to increase transparency and provide a more comprehensive picture of the MNE as it relates to transfer pricing documentation.

In the most recent budget, the Federal Government also confirmed its intention to introduce legislation requiring CbC reporting in order to strengthen transfer pricing documentation.

The requirement to file will apply only to MNE’s with total annual consolidated revenue greater than or equal to EUR750 million and the first exchanges of CbC reports are expected to occur by June 2018 and will be required for taxation years beginning after 2015.

For more information, please see the news release from the OECD here or contact Melinda Nguyen-Raybould at 416.515.3805 or [email protected], or your local MNP Advisor.