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Cross-border Tax Talks
September 07, 2023
Poutine Routine: Canada’s Pillar Two, DSTs, with G(AA)Ravy on top
Doug McHoney (PwC's International Tax Services Global Leader) and Ken Buttenham meet up in PwC’s Washington, D.C.. studio. Ken leads PwC Canada’s International Tax Practice from Toronto. Doug and Ken kick off with a discussion on Doug’s favorite Canadian food, then dive into the Canadian Pillar Two proposals, discussing the Global Minimum Tax Act (GMTA), UTPR, IIR, QDMTT, compliance, the GloBE Information Return, and tax incentives. They also cover digital services taxes (DSTs), the excessive interest and financing expenses limitation (EIFEL) rules, and the Canadian General Anti-Avoidance Rule (GAAR).
Timestamps:
- 2:35 - What are the specifics of Canada’s Pillar Two proposals under the Global Minimum Tax Act, released August 4?
- 5:40 - How does the Canadian legislative process work? When might legislation formally pass?
- 8:20 - How will Canada incorporate & interpret current OECD administrative guidance, or future guidance?
- 11:00 - Any insights into how Canada might interpret the Qualified Domestic Minimum Top-up Tax (QDMTT)?
- 14:40 - How do the Global Minimum Tax Act and the Canadian Income Tax Act rules interact?
- 16:00 - What’s the landscape in Canada for tax incentives and could they be considered Qualified Refundable Tax Credits?
- 17:40 - What are the general rules for the GloBE Information Return and the QDMTT return?
- 20:00 - Any advice for taxpayers regarding the Pillar Two comment period that closes September 29, 2023?
- 21:30 - What do Canada’s reproposed digital services tax (DST) rules look like?
- 24:10 - What does the Canadian DST do?
- 26:50 - What is the historical context and future of the excessive interest and financing expenses limitation (EIFEL) rules?
- 29:26 - Any advice for taxpayers on these EIFEL rules?
- 32:56 - What is the framework and history of the Canadian General Anti-Avoidance Rule (GAAR)?
- 34:05 - How did the GAAR purpose test change?
- 34:30 - What are the changes to GAAR economic substance?
- 36:00 - What are the penalties if a taxpayer is subject to these GAAR rules?
Speakers
International Tax Services Global Leader, PwC US
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