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- Title
PROFIT SHIFTING BY CANADIAN MULTINATIONAL CORPORATIONS: PROSPECTS OF REVERSAL UNDER CANADA'S COUNTRY-BY-COUNTRY REPORTING RULES.
- Authors
Eyitayo, Oladiwura Ayeyemi
- Abstract
This article examines the prospects of Canada's Draft Country-by- Country Reporting Rules. The article analyses the substantive provisions, objective and practicalities of application of the rules, which are aimed at eliminating base erosion and profit shifting in Canada. The author submits that the Draft Rules are insufficient to combat base erosion and profit shifting. The author proposes amendments to the "threshold", "appropriate use", and "confidentiality" clauses of the Rules. These changes are in line with the objective behind the enactment of the Rules, which is to prevent base erosion and profit shifting in Canada. The author also argues for a replacement of the arm's length principle, the current approach for taxing multinational corporations in Canada with the unitary taxation (formulary apportionment) method.
- Subjects
CANADA; CORPORATION law; INTERNATIONAL business enterprises; UNITARY taxation; CONGLOMERATE corporations; FOREIGN ownership of business enterprises; FOREIGN trade promotion; COMMERCIAL law; LAW
- Publication
Dalhousie Journal of Legal Studies, 2018, Vol 26, p79
- ISSN
1188-4258
- Publication type
Article