•  
  •  
 
Dalhousie Journal of Legal Studies

Article Title

Profit Shifting by Canadian Multinational Corporations: Prospects of Reversal under Canada's Country-by-Country Reporting Rules

Abstract

This article examines the prospects of Canada’s Draft Country-by-Country Reporting Rules. The article analyses the substantive provisions, objective and practicalities of application of the rules, which are aimed at eliminating base erosion and profit shifting in Canada. The author submits that the Draft Rules are insufficient to combat base erosion and profit shifting. The author proposes amendments to the “threshold”, “appropriate use”, and “confidentiality” clauses of the Rules. These changes are in line with the objective behind the enactment of the Rules, which is to prevent base erosion and profit shifting in Canada. The author also argues for a replacement of the arm’s length principle, the current approach for taxing multinational corporations in Canada with the unitary taxation (formulary apportionment) method.

Creative Commons License

Creative Commons Attribution-Noncommercial-No Derivative Works 3.0 License
This work is licensed under a Creative Commons Attribution-Noncommercial-No Derivative Works 3.0 License.

This document is currently not available here.

Share

COinS