The Canada Revenue Agency (CRA) recently confirmed that a Canadian taxpayer must file a 2016 country-by-country (CbC) report as a constituent entity (CE) in Canada - even if a CbC report is filed by the group's ultimate parent entity (UPE) or surrogate parent entity (SPE) in another jurisdiction - in all cases where (1) Canada does not have an activated exchange agreement with the jurisdiction of the UPE or SPE by 31 December 2017 or (2) has an activated agreement but it is not in effect for fiscal years beginning 1 January 2016.
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