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May 11, 2022

Canada's proposed hybrid mismatch arrangement rules discussed

Canada's federal government released draft legislative proposals and accompanying explanatory notes (referred to herein as the hybrid mismatch rules) on April 29, to address certain hybrid mismatch arrangements. As per the explanatory notes, these rules are intended to implement the recommendations in, and be generally consistent with, the Final Report under Action 2 of the Organisation for Economic Co-operation and Development/G20's Base Erosion and Profit Shifting Project (the BEPS Action 2 Report). The hybrid mismatch rules will apply to payments arising on or after July 1, 2022, with no grandfathering for existing arrangements. Interested parties are invited to send comments on these draft proposals to by June 30.

A Tax Alert prepared by Ernst & Young Canada, and attached below, provides additional details.


Full text of Tax Alert