Canada - Master File, Local File and Country-by-Country Reporting: A Canadian Perspective
- J.S. Wilkie
- International Transfer Pricing Journal, 2016 (Volume 23), No 2
- 17 March 2016
The author considers the broad compatibility of the master file, local file and country-by-country reporting regimes with existing Canadian tax law, first by outlining the essential elements of these regimes and then testing them with reference to the main elements of the investigatory powers of Canadian tax authorities and taxpayers’ reporting obligations under the Income Tax Act.