Canada Update: DST, Anti-Hybrid, Earnings Stripping and GAAR

The 2023 Fall Economic Statement Implementation Act (Bill C-59) tabled in Parliament on November 21, 2023, contains various tax measures, including revised legislation for Canada’s digital services tax (“DST”), hybrid mismatch rules, and excessive interest and financing expenses limitation (“EIFEL”) rules, tax support for green initiatives, general anti-avoidance rule (“GAAR”) amendments, and a share buyback tax (1st Sess, 44th Parl, 2023 (first reading Nov. 30, 2023); see Explanatory Notes). We anticipate that Bill C-59 will be enacted into law in the first quarter of 2024 – though many of its provisions will have retroactive application – and ...