Information returns relating to foreign affiliates

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Information returns relating to foreign affiliates for tax years beginning before 2021 (T1134 Version 2012/2017)

Note: The following information pertains to T1134 Version 2012/2017. For tax years that begin after 2020, refer to T1134 Version 2021 for guidance.

Do you have to file a return?

Form T1134 consists of a summary and supplements. A separate supplement must be filed for each foreign affiliate (non-resident corporation or non-resident trust) of the taxpayer or partnership that is at any time in the year either of the following:

  • controlled foreign affiliate
  • non-controlled foreign affiliate

Only the lowest-tiered Canadian corporation has to report on its foreign affiliate. For example, if Canco 1 owns 100% of the shares of Canco 2 and if Canco 2 owns 100% of the shares of Foreignco 1, only Canco 2 has to report, even though Foreignco 1 is a foreign affiliate of Canco 1.

A non-resident trust that is considered to be resident under section 94 of the Income Tax Act for purposes of Part I (discretionary trust) is also considered resident for purposes of the foreign affiliate reporting rules. As a result, such a trust may have to file Form T1134.

What has to be reported?

The required information is described in detail on form T1134, Information Return Relating to Controlled and Not-Controlled Foreign Affiliates for tax years beginning before 2021 (T1134 Version 2012/2017):

  • T1134 Summary – Part I, Section 1 and 2 of the summary must be completed for each reporting entity. Part I, Section 3 of the summary must be completed by the reporting entity who is reporting on one or more controlled foreign affiliates. (This information is required once for a group of persons that are related to each other. Another person/partnership of the related group can report the information in this section).
  • T1134 Supplement – Part II, Section 1, 2, 3, 4A and Part IV of a separate supplement must be filed for each foreign affiliate. A separate supplement must be filed in full for each controlled foreign affiliate.

Filing deadline

The applicable form is due within 15 months of the end of the reporting taxpayer's tax year or, in the case of a partnership, fiscal period.

Note

For tax years that begin in 2020, Form T1134 must be filed within 12 months of the end of the reporting taxpayer's tax year or, in the case of a partnership, fiscal period. For tax years that begin after 2020, the 2021 version of the Form T1134 must be filed within 10 months of the end of the reporting taxpayer's tax year or, in the case of a partnership, fiscal period.

Can I Efile this form?

Corporations and Partnerships can attach supporting documentation such as financial statements related to EFILED Foreign Reporting Returns as of October 21, 2019, via your tax preparation software with the Submit electronic documents service.

By filing electronically, you will receive a confirmation number at once to tell you that the Canada Revenue Agency (CRA) has received your form(s).

For paper filers, please send the original return, amended return, or any additional information to the address provided on the back of the form. See the instructions in the Amending a T1134 return section.

For reporting entities that are individuals and trusts, a paper copy of this form must be filed separately from your income tax return.

Amending a T1134 return

Amendments include any changes to information previously provided on a summary or a supplement, the cancellation of any supplement(s) previously filed, and the addition of any new supplement(s) omitted from the original filing.

If you have paper-filed your T1134 return, any amendments necessary to any information contained in the summary or in the supplements of the T1134 return will require a resubmission of the entire paper filing. DO NOT E-file amendments to paper-filed returns. Clearly identify the nature of the amendment by writing “AMENDED”, “CANCELLED”, or “ADDITIONAL” as appropriate at the top of each summary or supplement being amended. Alternatively, you may detail the amendments required in a cover letter to accompany the summary or supplement(s) that are being amended.

If you have filed your T1134 return electronically, any amendments necessary to any information contained in the summary or the supplements of the T1134 return should also be submitted electronically. However, if you choose to amend your T1134 return by paper, you must detail the amendments required in a cover letter and follow the instructions for paper filers as described above.

Administrative policies

Do not file Form T1134 if the total cost amount to the reporting entity at any time in the year of the interest in all foreign affiliates was less than $100,000 and the foreign affiliate is dormant or inactive for the affiliate's tax year ending in your tax year.

The threshold for a dormant or inactive foreign affiliate (for which reporting is not required) has been raised. The threshold is changed from "less than $10,000 gross receipts, and assets with a total fair market value of no more than $100,000" to "less than $25,000 gross receipts, and assets with a total fair market value of no more than $1,000,000". This will reduce the number of foreign affiliates for which reporting is required.

Reporting on the organizational structure (Part I, Section 3)

If you are reporting on one or more controlled foreign affiliates, Part I, Section 3 requires you to produce information on the organizational structure once for a group of persons that are related to each other. Enter this information into the specific data fields.

Administrative relief

Administrative relief from reporting is provided for short tax years, for example, where there is a deemed year-end due to a change of control. Reporting for the normal 12 month tax year or fiscal period will be sufficient if the information that would otherwise be reported for the short tax year or fiscal period, for example, less than 12 months, is included on the T1134 return that is filed for the normal year-end. A separate filing for the short tax year is not required. This is consistent with the policy that has been in place for form T106, Information Return of Non-Arm's Length Transactions with Non-Residents.

We understand that if you are reporting on a tiered structure of foreign affiliates in this new format, area B of Section 3 would require you to complete several lines of repetitive information. To reduce this filing burden, the CRA will accept information limited only to each foreign affiliate of the reporting entity that has a direct equity percentage in any other foreign affiliate of the reporting entity.

If the foreign affiliate of the reporting entity does not have a direct equity percentage in another foreign affiliate of the reporting entity, but does have an equity percentage, you are not required to provide information regarding this situation in area B of Section 3.

In summary, when completing Part I, Section 3B, list the name and country code of the country of residence of each foreign affiliate of the reporting entity that has a direct equity percentage in any other foreign affiliate of the reporting entity. Include the foreign affiliate's equity percentage and direct equity percentage in the other foreign affiliate.

Information returns relating to foreign affiliates for tax years beginning in 2021 or later (T1134 Version 2021)

Note: The following information pertains to T1134 Version 2021. For tax years that begin before 2021, refer to T1134 Version 2012/2017 for guidance.

Do you have to file a return?

Form T1134 consists of a summary and supplements. A separate supplement must be filed for each foreign affiliate (non-resident corporation or non-resident trust) of the taxpayer or partnership that is at any time in the year either of the following:

  • controlled foreign affiliate
  • non-controlled foreign affiliate

Only the lowest-tiered Canadian corporation has to report on its foreign affiliate. For example, if Canco 1 owns 100% of the shares of Canco 2 and if Canco 2 owns 100% of the shares of Foreignco 1, only Canco 2 has to report, even though Foreignco 1 is a foreign affiliate of Canco 1.

A non-resident trust that is considered to be resident under section 94 of the Income Tax Act for purposes of Part I (discretionary trust) is also considered resident for purposes of the foreign-affiliate reporting rules. As a result, such a trust may have to file Form T1134.

What’s New for T1134 Version 2021?

The form’s name was updated to T1134, Information Return Relating to Controlled and Non-Controlled Foreign Affiliates as opposed to the use of Not-Controlled Foreign Affiliates in prior versions.

The 2021 version of the T1134, Information Return Relating to Controlled and Non-Controlled Foreign Affiliates introduces a number of changes in the required information. A detailed description of the information required can be found on the form, some of the key changes are highlighted in the following paragraphs. 

  • T1134 SummaryPart I, Section 1, 2 and 3 of the summary must be completed for each reporting entity. For taxation years or fiscal periods that begin after 2020, Form T1134 version 2021 collects additional information that was not previously collected on the 2012/2017 version of Form T1134. The new tables and options for reporting entities in the T1134 Summary are outlined below:
    • On page 1 of the T1134 Summary Form, the reporting entity now has the option to either file as “One reporting entity” or “A group of reporting entities that are related to each other”. The group filing option is only applicable to reporting entities that are:
      • related to each other;
      • have the same taxation year-end; and
      • report in Canadian dollars or in the same functional currency.
      This group filing option permits one reporting entity to act as the representative reporting entity for the related Canadian group and to file only one set of T1134 Summary and Supplements for all foreign affiliates that any one of its members would have otherwise been required to file. The T1134 Summary, Part I, Section 3, Table A. Group of reporting entities that are related to each other, is a new table that identifies the members of the related Canadian group if the group filing option has been selected. If you are not opting for the group filing, then do not fill out table A of section 3 under Part I.
    • T1134 Summary, Part I, Section 3, Table B. Other Information, is a new table that requires the reporting entity(-ies) to indicate if they have been involved in any reorganization transactions at the Canadian level.
    • T1134 Summary, Part I, Section 3, C. Organizational Chart, has remained similar to the previous version of the T1134 with only a few additions:
      • An additional question asking if the reporting entity is submitting a group organizational chart for the required information (i.e. electronic pictorial group organizational chart). If yes, then the reporting entity is not required to complete the information in Section 3, C. Organizational Chart, Tables i) through iv).
      • Section 3, C. Organizational Chart, Tables i) and ii)  have remained the same as the previous version of T1134 with the exception of requesting the Taxpayer Identification Number for non-residents and whether a T1134 Supplement was not filed due to the dormancy threshold.
    • T1134 Summary, Part I, Section 3, D. Dormant foreign affiliates, is a new table and is to be completed in respect of any foreign affiliate(s) that meet the dormancy thresholds such that no T1134 Supplement is required to be filed. In cases where the reporting entity or representative reporting entity chooses to fill out section 3. C. Organizational Chart in lieu of providing the same in a pictorial format, this information is required for each foreign affiliate identified as “dormant” in the previous section 3. C. Organizational Chart, Tables i) or ii). The dormancy thresholds have also been revised for filing periods after 2020 (see Administrative policies below).
    • T1134 - Summary, Part I, Section 3, E. Lower-tier Non-Controlled Foreign Affiliates, is a new table requesting information on transactions and events that affect the surplus account balances of lower-tier non-controlled foreign affiliate(s) that are held indirectly through other non-controlled foreign affiliate(s). It is not necessary to file a T1134 Supplement in respect of these lower-tier non-controlled foreign affiliates.
  • T1134 Supplement – Other than foreign affiliates that meet the dormancy thresholds or are indirectly held through another non-controlled foreign affiliate(s) (see above), Part II, Section 1, 2, 3A, and Part IV of a separate supplement must be filed for each foreign affiliate. A separate supplement must be filed in full for each controlled foreign affiliate; this includes information required in Part II Section 3.B. and Part III of the supplement.

    Similar to the T1134 Summary, for taxation years or fiscal periods that begin after 2020, Form T1134 supplement version 2021 collects additional information that was not previously collected on the 2012/2017 version of Form T1134. The new tables in the T1134 Supplement are outlined below:
    • T1134 Supplement, Part II, Section 1, B. Capital Stock of foreign affiliate, has four new tables that require the reporting entity(-ies) to indicate whether they have a direct ownership (Table i) or indirect ownership (Table iv) in the foreign affiliate and if they have a direct ownership in the foreign affiliate, they are also required to provide details of their stock ownership in the FA’s Common Shares (Table ii) and/or Preferred Shares (Table iii).
    • T1134 Supplement, Part II, Section 1, C. Other information of foreign affiliate, is also a new table requesting the reporting entity(-ies) to provide information on equity percentages, qualifying interests, certain debts, tracking interests, and elections filed with respect to this foreign affiliate.
    • T1134 Supplement, Part II, Section 1, D. Foreign affiliate dumping rules, is another new table applicable if the reporting entity(-ies) is a Corporation Resident in Canada (CRIC) for purposes of section 212.3.
    • T1134 Supplement, Part II, Section 2, Financial information of the foreign affiliate, has remained similar to the prior version of Form T1134. However, the requirement to provide unconsolidated financial statements in respect of each foreign affiliate will only apply to foreign affiliates in which a reporting entity holds at least 20% of the voting shares. The requirement to specify the three financial statement markers of total assets, accounting net income before tax, and income or profits tax paid or payable on income have been removed from Form T1134 version 2021.
    • T1134 Supplement, Part II, Section 3 A. Surplus accounts of foreign affiliates, has remained similar with the exception of the newly added questions identifying if any elections were made to change the normal surplus ordering rules, the amount of all dividends paid by the foreign affiliate, and whether the upstream loan rules were applicable to the foreign affiliate.
    • T1134 Supplement, Part II, Section 3 B. Surplus accounts and share transactions of controlled foreign affiliates, has changed from previously being a narrative description of the transformation transactions to specific yes or no questions regarding the transformation transactions and the applicable sections of the Act involved.
    • T1134 Supplement, Part III, Section 1, Employees, has changed from being employees per business to simply the total number of full-time employees or employee equivalents employed throughout the year with multiple ranges to select from. In addition, there is a new question in regards to services provided by persons in the context of the definition of an “investment business”.
    • T1134 Supplement, Part III, Section 2, Composition of revenue, has remained similar to the prior version. However, the reporting entity is required to separate out the gross revenue between arm’s length sources and non-arm’s length sources and answer an additional question indicating if the reporting entity is providing a breakdown of each income category or not.
    • T1134 Supplement, Part III, Section 3, Foreign accrual property income (FAPI) or Foreign accrual property loss (FAPL) or Foreign accrual capital loss (FACL), has changed from the prior version. In addition to stating the amount of FAPI earned by the foreign affiliate during its taxation year, the reporting entity (-ies) also needs to indicate if FAPL and/or FACL  incurred – either in the current year or in prior years – have been carried over and applied to reduce FAPI in other years.
    • T1134 Supplement, Part III, Section 4, Income included in income from an active business, is similar to the prior version’s Part III, Section 5 however, some of the previous questions have been condensed into one and a few new questions were added.

What has to be reported?

The required information is described in detail on Form T1134, Information Return Relating to Controlled and Non-Controlled Foreign Affiliates for tax years beginning in 2021 or later (T1134 Version 2021):

  • T1134 Summary – Part I – other than Section 3.A - of the summary must be completed for each reporting entity.  If a group of reporting entities that are related to each other chooses to file as a group, then Part I, Section 3.A must also be completed to identify each reporting entity that is a member of the group.  With the group filing option, only the representative reporting entity that is filing Form T1134 on behalf of the related Canadian group needs to be identified in Part I Section 1 and 2 of the Summary.
  • T1134 SupplementPart II, Section 1, 2, 3A and Part IV of a separate supplement must be filed for each foreign affiliate. A separate supplement must be filed in full for each controlled foreign affiliate.

Filing deadline

For tax years that begin in 2020, Form T1134 must be filed within 12 months of the end of the reporting taxpayer's tax year or, in the case of a partnership, fiscal period. For tax years that begin after 2020, Form T1134 must be filed within 10 months of the end of the reporting taxpayer's tax year or, in the case of a partnership, fiscal period.

For taxation years or fiscal periods that began before 2021, please use the previous 2012/2017 version of the Form T1134 as released on November 28, 2017. 

Can I Efile this form?

Corporations and Partnerships can attach supporting documentation such as financial statements related to EFILED Foreign Reporting Returns as of October 21, 2019, via your tax preparation software with the Submit electronic documents service.

By filing electronically, you will receive a confirmation number at once to tell you that the Canada Revenue Agency (CRA) has received your form(s).

For paper filers, please send the original return, amended return, or any additional information to the address provided on the back of the form.

For reporting entities that are individuals and trusts, a paper copy of this form must be filed separately from your income tax return.

Individuals can Efile and Netfile the T1134 forms electronically for the 2021 and later taxation years as of February 7, 2022.

In the future, the CRA will make the electronic filing of Form T1134 available for Trusts and will announce when the service becomes available.

Amending a T1134 return

Amendments include any changes to information previously provided on a summary or a supplement, the cancellation of any supplement(s) previously filed, and the addition of any new supplement(s) omitted from the original filing.

Once you have filed your T1134 return for a taxation year, either as a group of related reporting entities or as one reporting entity, the filing option so adopted will remain for that taxation year.

If you have paper-filed your T1134 return, any amendments necessary to any information contained in the summary or in the supplements of the T1134 return will require a resubmission of the entire paper filing. DO NOT E-file amendments to paper-filed returns. Clearly identify the nature of the amendment by writing “AMENDED”, “CANCELLED”, or “ADDITIONAL” as appropriate at the top of each summary or supplement being amended. Alternatively, you may detail the amendments required in a cover letter to accompany the summary or supplement(s) that are being amended.

If you have filed your T1134 return electronically, any amendments necessary to any information contained in the summary or the supplements of the T1134 return should also be submitted electronically. However, if you choose to amend your T1134 return by paper, you must detail the amendments required in a cover letter and follow the instructions for paper filers as described above.

Administrative policies

For tax years or fiscal periods that begin after 2020, the criteria to qualify for the exemption from filing the T1134  supplement for “dormant” or “inactive” foreign affiliate has been revised and will be applied at the individual legal entity level. Do not file Form T1134 Supplement in respect of a foreign affiliate if the total cost amount to the reporting entity at any time in the year of the interest in that foreign affiliate was less than CAD $100,000 and that foreign affiliate is “dormant” or “inactive” for the affiliate's taxation year ending in your taxation year. Where a group of related reporting entities are electing to file under the group filing option, each reporting entity within the related group is required to determine whether a foreign affiliate meets the criteria to be considered as a “dormant” affiliate for the reporting period based on that reporting entity’s total cost amount in that foreign affiliate.  Unless each member of the related Canadian group meets the less than CAD $100,000 threshold for the total cost amount in that foreign affiliate, a separate T1134 Supplement will need to be filed in respect of that foreign affiliate.

The threshold for a dormant or inactive foreign affiliate (for which reporting is not required) has been raised for tax years that begin after 2020. The threshold is changed from "less than $25,000 gross receipts, and assets with a total fair market value of no more than $1,000,000" to "less than $100,000 gross receipts, and assets with a total fair market value of no more than $1,000,000". This will reduce the number of foreign affiliates for which reporting is required.

Administrative relief

Administrative relief from reporting is provided for short tax years, for example, where there is a deemed year-end due to a change of control. Reporting for the normal 12 month tax year or fiscal period will be sufficient if the information that would otherwise be reported for the short tax year or fiscal period, for example, less than 12 months, is included on the T1134 return that is filed for the normal year-end. A separate filing for the short tax year is not required. This is consistent with the policy that has been in place for form T106, Information Return of Non-Arm's Length Transactions with Non-Residents.

For tax years or fiscal periods that begin after 2020, there is an option to electronically submit a pictorial of the organizational chart which will significantly reduce the filing burden if you are reporting on a tiered structure of foreign affiliates in the T1134 Summary, Part I, Section 3, C. Organizational Chart, Tables i) through iv).

If you choose to fill out Part I, Section 3, C. Organizational chart, instead of providing the organizational chart in pictorial format, the CRA will accept information limited only to each foreign affiliate of the reporting entity that has a direct equity percentage in any other foreign affiliate of the reporting entity. If the foreign affiliate of the reporting entity does not have a direct equity percentage in another foreign affiliate of the reporting entity, but does have an equity percentage, you are not required to provide information regarding this situation in Part I, Section 3, C. Organizational chart, table (ii). In summary, when completing Part I, Section 3.C. table (ii), list the name and country code of the country of residence of each foreign affiliate of the reporting entity that has a direct equity percentage in any other foreign affiliate of the reporting entity. Include the foreign affiliate's equity percentage and direct equity percentage in the other foreign affiliate.

However, the CRA will no longer allow one reporting entity within a related group to report the information required in Part I, Section 3, C. Organizational chart on behalf of the group; that is, if the related Canadian group chooses not to take advantage of the group filing option.

Forms and Publications

You can access both the 2012/2017 version of the T1134 for tax years beginning before 2021, and the 2021 version of the T1134 for tax years beginning in 2021 or later by viewing the T1134 Information Return Relating To Controlled and Non-Controlled Foreign Affiliates page.

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