04 October 2016 Canada's proposed legislative amendments may tax cross-border notional cash pooling arrangements The Department of Finance on July 29, released for public comment a package of draft legislative proposals and explanatory notes relating to a number of measures that were previously announced in the 2016 federal budget. Among other measures, the package would expand the back-to-back loan rules, which may impact a broad range of cross-border cash pooling arrangements. While the tax effectiveness of cross-border cash pooling has already been reduced in past years, the proposed measures, if implemented, may further restrict the use of cash pooling arrangements. A Tax Alert prepared by Ernst & Young Canada, and attached below, provides additional details. Document ID: 2016-1692 |
