A Canadian subsidiary, which prepared its consolidated financial statements in accordance with IFRS, also prepared its unconsolidated financial statements for its tax return purposes using IFRS, but applied IFRS 9 (re fair value accounting) in those statements but not in its consolidated statements. The effect was to boost its equity amount for thin cap purposes by the increase in the fair market value of its investment in subsidiaries (with that increment estimated to equal their net income for the relevant years).
In rejecting this approach, the Directorate stated:
[C]onsistency between the consolidated financial statements and unconsolidated financial statements… is expected… [in order] to avoid the use of financial statements as a tax planning tool…. [T]he Taxpayer should not be able to adopt IFRS 9 in the unconsolidated financial statements… until the time the Taxpayer adopts the same standard in its consolidated financial statements.