Master File, Local File and Country-by-Country Reporting: A Canadian Perspective
Journal
Country
Canada
Published Date
Issue
International Transfer Pricing Journal 2016 (Volume 23), No. 2
Document
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.