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.
- 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.
- A Canadian multinational should present its request for relief under s. 220(2.1) to its Tax Services Office in advance of the filing due-date of the subject form.
- CRA will consider each request based on the circumstances of that request.