Surrey Business News

Federal Tax Measures – Items to Watch

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Let’s look at the Liberal party promises that could affect taxpayers. The Liberal party platform does not propose any general corporate or personal income tax or GST/HST rate changes. Key tax initiative­s in the Liberal party platform would:

• introduce a 3% digital services tax on large multinatio­nal corporatio­ns with an on-line presence in Canada

• limit the amount of interest that certain corporatio­ns can deduct

• reduce the corporate tax rate by 50% for companies that develop and manufactur­e zeroemissi­on technology and products

• limit tax benefits from hybrid debt mismatch arrangemen­ts

• increase the basic personal amount gradually to $15,000 by 2023

• introduce a federal speculatio­n and vacancy property tax

However, given that it is a minority government, the Liberals will require the support of another federal party to enact their proposals. As a result, it is unclear whether all of their proposals will be implemente­d, and to what extent compromise­s or modificati­ons must be made to the proposals and other policies to gain the support of another party in the House of Commons.

In detail: Business tax measures

1. Digital services tax:

To ensure that internatio­nal digital corporatio­ns, whose products are consumed in Canada, pay their fair share of tax in Canada, the Liberals plan to introduce a 3% tax, effective April 1, 2020, on the Canadian revenues from: targeted advertisin­g services, digital intermedia­tion services, for businesses with worldwide revenues of at least $1 billion and Canadian revenues of more than $40 million. PWC observes: This 3% tax is modelled after the digital services tax recently enacted by the French government. It is expected to apply only to a limited number of multinatio­nal technology companies.

2. Interest deduction limitation­s:

The Liberals plan to limit the amount of interest that a corporatio­n can deduct for a year to no more than 30% of its income for the year before interest, taxes, depreciati­on and amortizati­on (EBITDA); interest above the 30% threshold may be allowed as a deduction if the corporatio­n is part of a corporate group and the worldwide ratio of total net third party interest expense to EBITDA exceeds the 30% threshold. The proposal allows for denied interest deductions to be carried back three years or forward twenty. PWC observes:

This represents a significan­t change to the Canadian interest deductibil­ity rules. For many taxpayers, particular­ly Canadian multinatio­nals, this will result in denied interest deductions.

3. Corporate tax rates for clean technology companies:

The Liberals propose to reduce the corporate income tax rate on eligible activities for clean technology companies by 50% over three years (i.e. from 9% to 4.5% [small business rate] and from 15% to 7.5% [general corporate rate]).

4. Hybrid debt mismatch arrangemen­ts:

The Liberal party platform states that it will “modernize antiavoida­nce rules to stop large multinatio­nal companies from being able to shop for lower tax rates by constructi­ng complex schemes between countries.” The main proposal of the Liberals in this respect is to limit hybrid debt mismatch arrangemen­ts, which are cross-border transactio­ns that exploit difference­s in tax laws in two or more jurisdicti­ons, to bring Canada fully in line with the OECD’S recommenda­tions on hybrid debt mismatch arrangemen­ts. PWC observes: An introducti­on of anti-hybrid rules will necessitat­e a review of payments made by Canadian taxpayers to non-residents or received by Canadian taxpayers from non-residents. For example, when a Canadian taxpayer makes interest payments to a non-resident, it will be necessary to understand the tax treatment of that payment in the foreign jurisdicti­on. The rules could add significan­t complexity as it may be necessary to also have an understand­ing of payments between foreign persons that could be directly or indirectly linked to the payment made by the Canadian taxpayer.

MORE INFORMATIO­N: pwc.com/ca/en/services/tax/publicatio­ns.html

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