Transfer pricing alert: Canada’s country-by-country legislation comes into force, CRA releases Form RC4649
On February 3, 2017, the Canada Revenue Agency (CRA) released the prescribed form for reporting country-by-country (CbC) information, Form RC4649, Country-by-Country Report. Form RC4649 is consistent with the model CbC report templates included in the Organisation for Economic Cooperation and Development’s (OECD) October 5, 2015 final report, and requires the following information to be provided for each tax jurisdiction: revenues (unrelated and related), income, taxes paid and accrued, stated capital, accumulated earnings, number of employees, tangible assets and certain information about each of the so-called “constituent entities”, including their primary activities.