Where a cash pooling arrangement in which a Canadian taxpayer may be a debtor is a “notifiable transaction”, would a filing requirement exist if the Canadian taxpayer’s participation in the arrangement commenced prior to November 1, 2023?
- CRA indicated that since the cash pooling constituted a series of transactions, the reporting obligation would arise on the first such transaction occurring after November 1, 2023, e.g., an interest payment.
If the cash pooling arrangement is a “notifiable transaction”, would a single reporting to describe the arrangement be sufficient?
- CRA indicated that since (again) the cash pooling arrangement was a series of transactions, the filing in respect of one element of the series would satisfy the filing requirement in respect of the whole series, provided that the filing describes the nature of the subsequent transactions, and whether they are recurring or not.