In this article – “Tax planning developments: Important international tax changes” – we review such factors as the proposed changes for international taxation in Canada in 2021; Canada’s continuing work with the OECD, G20 and a number of other countries on significant international tax reform proposals; proposed new limits on interest deductibility; proposed anti-hybrid measures designed to reduce the tax advantages currently available in some situations as a result of an entity being treated differently by different jurisdictions; a proposed digital services tax on digital services that rely on the engagement, data and content contributions of Canadian users; an international tax reform proposal that provides new taxing rights for market jurisdictions to obtain a share of residual profit of a multinational enterprise; and an International Framework agreement that involves a proposed global minimum tax.

This article is authored by Patrick Marley, partner and co-chair, Osler’s Tax Group, and Ilana Ludwin, associate, Tax Group.

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Our Legal Year in Review, published December 7, 2021, provides general information only and does not constitute legal or other professional advice. Specific advice should be sought in connection with your circumstances.

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