Taxpayers have made six proposals to the Canadian government to maintain the international competitiveness of the economy, including the elimination of withholding tax on intercompany dividends in the Canada-US tax treaty, the introduction of a participation exemption for foreign dividends and the establishment of a system that would allow for loss transfer or group loss relief
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Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies
While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model
MNEs now face a shift from modelling to execution as the side‑by‑side deal forces tax teams to upgrade systems, harmonise data, and prevent costly pillar two mismatches