A review of Canada’s foreign affiliate dumping provisions – prevention of multinational surplus stripping

Mark Woltersdorf and Larry Nevsky consider the detail of the provisions found in Section 212.3 of the Income Tax Act, including their purpose and some application examples.

Countries around the globe have increased their efforts to combat aggressive international tax planning arrangements. The Organisation for Economic Cooperation and Development (OECD) has led the charge with the Base Erosion and Profit Shifting (BEPS) project and its close companion, the multilateral instrument.