Income Tax Mandatory Disclosure Rules Consultation

Current Status: Open

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A tax system in which everyone pays their fair share requires action on multiple fronts. This includes strengthening the Canada Revenue Agency’s ability to curtail tax evasion and aggressive tax avoidance. In support of this goal, the government is consulting on proposals to enhance Canada’s income tax mandatory disclosure rules. Details about this proposal are available in the Budget 2021 Annex 6 entitled Tax Measures: Supplementary Information.

Specifically, this consultation will address changes proposed to the Income Tax Act’s reportable transaction rules, a new requirement to report notifiable transactions, and a new requirement for specified corporations to report uncertain tax treatments.  

We also welcome any additional comments or feedback relevant to the scope of this consultation.

Who is the focus of this consultation?

Through this consultation, we want to hear from interested stakeholders including tax practitioners, civil society groups and members of the public. In submitting your comments, please include:

Participate through email

Due to COVID-19 public health considerations, email submissions are preferred. Send us your comments at with “MDR Consultation” as the subject line.

Should you wish to provide comments by mail, please direct your submission to the attention of the Tax Policy Branch.

What’s next?

We’ll be collecting your feedback and will consider your input alongside the analysis of departmental officials to help inform decisions on the proposed enhancement of Canada’s income tax mandatory disclosure rules.

Information received through this comment process is subject to the Access to Information Act and the Privacy Act. Those providing comments are asked to indicate clearly the name of the individual or the organization that should be identified as having made the submission. In order to respect privacy and confidentiality, please advise when providing your comments whether you:

Should you indicate that your comments, or any portions thereof, be considered confidential, the Department of Finance will make all reasonable efforts to protect this information.

Related links

Budget 2021 Tax Measures: Supplementary Information Annex

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