In the context of Canada’s BEPS commitment to exchange information with other countries on certain tax rulings, effective April 1, 2016 IC 70-6 will be revised to indicate that summaries of the contents of the following categories of rulings may be exchanged with the countries of residence of the immediate and ultimate parent and certain other parties (which countries may then ask to receive relevant portions in more detail) - re:
a) preferential regimes (for Canada, including international shipping and certain foreign life insurance operations of a Canadian company);
b) cross-border transfer pricing;
c) downward adjustment not directly reflected in the taxpayers’ accounts;
d) permanent establishments; and
e) related party conduits.