Global

Details

  • Service: Tax, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 8/2/2013

Canada - “Reportable transaction” return due 23 October 2013 

August 2: The due date for the first “reportable transaction information return” (Form RC312) required under Canada’s new federal aggressive tax planning (ATP) reporting regime is 23 October 2013.

Form RC312 must normally be filed on or before 30 June following the calendar year in which a transaction first became a "reportable transaction.”


However, under a transitional provision, transactions that would have been required to have been reported before 1 July 2012 will be considered to be filed on time if Form RC312 is filed before the day that is 120 days after the date when the ATP reporting regime legislation received Royal Assent on 26 June 2013.


The new ATP reporting regime generally takes effect for "reportable transactions" entered into after 2010 or to a series of transactions completed after 2010. Generally, a reportable transaction is an avoidance transaction or a series of avoidance transactions (as defined for purposes of GAAR in subsection 245(3) of the Act) if two of three hallmarks are present.


Read a July 2013 report prepared by the KPMG member firm in Canada: Due Date for First Aggressive Tax Planning Return Fast Approaching




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