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1. • Does not allow income tax returns

     • Canada does not allow income tax returns to be filed on a consolidated basis for affiliated or related corporations.
     www.dlapiperintelligence.com › goingglobal › tax

     Consolidation in Canada - DLA Piper Guide to Going Global

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   Can a corporation file a consolidated tax return in Canada?

   • Canada does not allow income tax returns to be filed on a consolidated basis for affiliated or related corporations.

   Consolidation in Canada - DLA Piper Guide to Going Global

   www.dlapiperintelligence.com/goingglobal/tax/index.html?t=07-consolidation&c=CA

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   Can a reorganization of a Canadian corporation be tax-deferred?

   • Divisive reorganizations of a Canadian corporation are possible to achieve on a tax-deferred basis in Canada, but if occurring outside a related group typically involve meeting various constraints as to how the existing Canco’s property is divided and substantial continuity of ownership requirements.

   Canadian Subsidiaries | Business Tax Canada

   businesstaxcanada.com/canadian-subsidiaries/

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   Is group taxation allowed in Canada?

   • Group taxation is not permitted. Canadian transfer pricing legislation and administrative guidelines are generally consistent with the OECD Guidelines. Statutory rules require that transactions between related parties be carried out under arm's-length terms and conditions.

   Canada - Corporate - Group taxation - Worldwide Tax Summaries Online

   taxsummaries.pwc.com/canada/corporate/group-taxation

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   Can a non-resident use a corporation in Canada?

   • Non-residents with significant Canadian business activities most commonly use a corporation (“Canco”) that is created under Canadian corporate law and is thereby resident in Canada for tax purposes to carry on Canadian business operations.

   Canadian Subsidiaries | Business Tax Canada

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3. taxsummaries.pwc.com › canada › corporateCanada - Corporate - Group taxation - Worldwide Tax Summaries ...

   taxsummaries.pwc.com › canada › corporate

   • Cached

   A ‘group ratio’ rule will allow a taxpayer to deduct interest in excess of the fixed ratio, where the taxpayer can demonstrate that the ratio of net third party interest to book EBITDA of its consolidated group is higher than the fixed ratio; in this case, the interest limitation would be based on the higher group ratio if the Canadian ...

4. businesstaxcanada.com › canadian-subsidiariesCanadian Subsidiaries | Business Tax Canada

   businesstaxcanada.com › canadian-subsidiaries

   • Cached

   Canada’s tax system does not allow group filing or consolidated returns: each Canadian entity within a related group is required to determine its own taxes owing and must file its own tax return, although discussed below under 5., Losses, some degree of self-help is permissible to match income in one Canco with tax shelter available in a ...

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5. www.dlapiperintelligence.com › goingglobal › taxConsolidation in Canada - DLA Piper Guide to Going Global

   www.dlapiperintelligence.com › goingglobal › tax

   • Cached

   Consolidation. Canada does not allow income tax returns to be filed on a consolidated basis for affiliated or related corporations. Last modified 14 Aug 2023. Download PDF.

6. www.internationaltaxreview.com › article › 2a69c3njsA group consolidation system for Canada | International Tax ...

   www.internationaltaxreview.com › article › 2a69c3njs

   Nov 1, 2010 · A group consolidation system for Canada | International Tax Review. November 01, 2010. Bill Maclagan. Under the Canadian taxation system, corporations are taxed on a separate entity basis. Each corporation must file its own tax return declaring its own loss or income.

7. www.canada.ca › en › revenue-agencyGuidance on Country-By-Country Reporting in Canada

   www.canada.ca › en › revenue-agency

   • Cached

   Purpose of this document. Background. Interpretation of Canadian CbC reporting legislation. Entities that are required to file in Canada. Exemptions from filing in Canada. Effective date of CbC reporting in Canada. Deadline for filing of the CbC Report. Filing a CbC Report with the CRA - Corporation Internet Filing (CIF)

8. www.abchamber.ca › policies › consolidated-incomeConsolidated Income Tax Filing for Corporate Groups in Canada

   www.abchamber.ca › policies › consolidated-income

   • Cached

   The current approach to taxation of corporate groups in Canada ignores the commonality of ownership principles and requires that owners undertake costly and complicated planning to allow for consolidation or transfers of losses and/or credits between members of a common corporate group.

9. www.canada.ca › corporation-income-tax-returnCorporation income tax return - Canada.ca

   www.canada.ca › corporation-income-tax-return

   • Cached

   The CRA has two types of corporation returns: T2 Corporation Income Tax Return – This is a nine-page return. Any corporation can use it. T2 Short Return – This is a two-page return plus one schedule. See Guide T4012, T2 Corporation Income Tax Guide, to check if you are eligible to use the T2 Short Return.