On September 23, the Canadian Federal Court of Appeal released the highly anticipated decision in Daishowa-Marubeni. Doug Richardson and Julie D’Avignon of Stikeman Elliott explain why the decision is of particular interest to every mining, energy and forestry company that has bought or sold assets in circumstances where reclamation or reforestation obligations were assumed by the purchaser as part of the sale.
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Despite the relief, Brazil’s government has also presented a bill which seeks to re-impose a tax burden on companies’ payroll, one local tax specialist told ITR
While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort