Proposed mandatory disclosure rules

Taxpayers, advisors, and promoters (and certain other parties) will be required to disclose relevant information on aggressive tax planning or transactions to the CRA, under proposed mandatory disclosure rules. Overall, the compliance burden for taxpayers, advisors, and promoters is anticipated to be significantly increased if these rules are enacted. These rules, introduced in Budget 2021, will apply to transactions once the draft legislation receives Royal Assent. 

Updated: May 11, 2023  

Taxpayers and their advisors should determine whether they’ll have new reporting requirements under incoming mandatory disclosure rules introduced as part of Bill C-47. The new mandatory disclosure rules, which will come into effect once the bill receives Royal Assent, contain the following changes: 

1. An expansion of the reportable transaction rules in the Income Tax Act (the Act), along with a significantly reduced reporting deadline; 
2. A new requirement to report notifiable transactions; 
3. A new requirement for certain corporations to report uncertain tax treatments; 
4. An extension of the normal reassessment period in non-compliance situations; and  
5. New related penalties (some of which accrue daily or weekly) 

Proposed mandatory disclosure rules

On February 4, 2022, the Department of Finance released draft legislation for public comment, which included changes to the mandatory disclosure rules.

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Download PDF [188 kb]