BEPS on Hybrids: A Canadian Perspective

Authors: Nathan Boidman and Michael N. Kandev

On March 19, 2014, the Organisation for Economic Co-operation and Development (OECD) released two discussion draft papers on hybrid mismatch arrangements in response to action 2 of the July 2013 action plan on base erosion and profit shifting (BEPS).

Co-authors Nathan Boidman and Michael Kandev discuss the March 19 hybrid drafts from a Canadian perspective and from a conceptual perspective to identify aspects that appear problematic.

Download this article.

Key Contacts



Federal Court of Appeal Says Funding Services Not Subject to GST/HST

Oct. 04, 2019 - In SLFI Group v Canada (2019 FCA 217), the Federal Court of Appeal (FCA) overturned a Tax Court of Canada (TCC) decision and ruled that a group of Canadian mutual funds (Funds) was not required to self-assess GST/HST on funding services provided by a U.S. entity, because these services were...

Extended Deadline for Québec Nominee Agreement Disclosure

Aug. 22, 2019 - As outlined in our e-communications of May 21, 2019, and August 12, 2019, Québec’s Ministry of Finance has introduced new rules regarding the disclosure of nominee agreements. The new disclosure requirement is relevant to nominee agreements involving one or more parties that are subject to Québec tax...