Document Type

Book Chapter

Publication Date

2024

Source Publication

Li, Jinyan, and Paul Lamarre. International Taxation in Canada. Fifth edition., LexisNexis, 2024.

Keywords

BEPS; hybrid mismatch; surplus strip; back-to-back arrangements; hybrid mismatch rules

Abstract

Canadian income tax rules applicable to foreign owned Canadian corporations have become increasingly complex, in part owing to the implementation of recommendations of the OECD/G20 BEPS project to address the issue of base erosion and profit shifting. This paper considers these anti-avoidance rules, including the hybrid mismatch arrangement rules, excessive interest and financing expense limitation rules and various surplus stripping rules.

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