17 May 2023 IFA Roundtable Q. 2, 2023-0964301C6 - Ukraine Russia FAs and Tax Reporting -- summary under Section 233.5

Will CRA grant any administrative relief in relation to the reporting requirements of Canadian multinationals for their subsidiaries in the Ukraine or Russia, such as country-by-country reporting, and forms T1134, given that financial reporting from these subsidiaries may not be available for 2022? CRA indicated:

  • For forms T1134 and T1141, the due diligence exception in s. 233.5 would be available if the taxpayer provides: the available information; the circumstances making the other information unavailable; and an explanation of the steps taken to obtain the information.
  • The application of s. 233.5 would also relieve any potential penalties under s. 162(5).
  • Relief may also be granted under s. 220(2.1), which could include the unconsolidated financial statements of the foreign affiliate that otherwise would have to be filed along with the T1134.
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