World Tax - Home
The comprehensive guide to the world's leading tax firms

Canada

Market overview Printer-friendly version

Tax authorities

International Tax Services Office
2204 Walkley Road, Ottawa ON K1A 1A8
Tel: +1 613 952 3741 / +1 613 954 9681 / +1 613 952 2344
Fax: +1 613 941 2505 / +1 613 952 3845 / +1 613 941 6905
Website: www.cra-arc.gc.ca

Tax rates at a glance

(As of June 30 2011)

Corporate income tax rate 16.5%
Capital gains tax rate 8.25%
Branch tax rate 25%
 
Withholding tax
Dividends 25%
Arm's length Interest 0%
Non-arm's length interest 25%
Rent, royalty or similar payments 25%
 
Net operating losses (years)
Carryback 3
Carryforward 20
  • The general federal corporate rate is 16.5% applicable to income earned by corporations other than Canadian-controlled private corporations. A general corporation typically includes public companies and their subsidiaries that are resident in Canada and Canadian resident private companies that are controlled by non-residents. As a result of provincial tax, the combined federal-provincial general corporate tax rate varies by province or territory, from 26.5% to 32.5%.
  • Only 50% of capital gains are included in income as taxable capital gains and taxed at the general corporate rate.
  • The branch tax rate applies to taxable income of a non-resident corporation not reinvested in Canada, and may be reduced by virtue of an applicable tax treaty. Where a treaty does not specifically reduce the branch tax rate, but reduces the withholding tax rate on dividends, the branch tax rate generally equals the reduced withholding tax rate on dividends.
  • Canada's tax treaties generally reduce the rate of withholding tax on dividends to 5% to 15% depending on the treaty and the status of the beneficial owner of the dividends.
  • Canada does not impose withholding tax on arm's-length interest (other than "participating debt interest") paid to a non-resident in any country.
  • Withholding tax applies to non-arm's length interest paid to a non-resident, but Canada's tax treaties generally reduce the rate of withholding on interest. Under the Canada-US Income Tax Convention, there is generally no withholding tax on interest (other than participating interest) paid to non-arm's length US residents.
  • Canada's tax treaties generally reduce and, in some cases, eliminate withholding tax on certain types of royalty payments.

Source: Professionals from Gowlings-Taxand

Canada

Michael McLaren, Michael Colborne and Mark Barbour
Thorsteinssons
Canada

Michael McLaren, Michael Colborne and Mark Barbour of Thorsteinssons discuss Canadian legal developments impacting international investment

[Show full article]

Tax

Blake Cassels & Graydon's tax lawyers regularly advise Canadian and international businesses on all aspects of tax and have for the past four years been voted International Tax Review's Canadian Tax Firm of the Year. The last 12 months has seen the ... [more]

Davies Ward Phillips & Vineberg has traditionally been known for the quality of advice from its tax practice in cross-border transactions. The Canadian and US tax groups are integrated to help clients achieve their North American tax planning objectives.The ... [more]

Deloitte is Canada's largest professional services firm. Andrew Dunn leads the tax practice, which has advised in some of Canada's largest M&A deals in the past year, covering a broad range of industries. It has also played a significant role in advising ... [more]

Ernst & Young expanded its tax practice significantly in 2011 by bringing in Fasken Martineau partner, David Robertson. The firm is at the forefront of the advice to foreign investors streaming into Western Canada and is active in a number of mining ... [more]

McCarthy Tétrault has really bolstered its corporate tax practice in the past year. Six partners have joined since October 2010: Chia-yi Chua and Wendy Brousseau from Fraser Milner Casgrain; Christian Meighen from Stikeman Elliott; Ron Mar, Edmund Gill ... [more]

Osler Hoskin & Harcourt has been tax litigation counsel to all five Canadian national banks. Partner Al Meghji has a strong presence in this practice area. Competitors explain that he's one of the "most experienced and well-regarded litigators in Canada". ... [more]

Stikeman Elliott lost two prominent partners in 2010, Susan Thomson retired in July and Christian Meighen joined McCarthy Tetrault as a partner in November. The firm added two associates in 2011. The practice was very busy in transactional matters in ... [more]

Goodmans partners Carrie Smit and Jon Northup advised Total E&P Canada in its $1.5 billion acquisition of UTS Energy Corporation in late 2010. The firm was also involved in a significant amount of conversion work as a result of the new rules on income ... [more]

KPMG has 32 offices in Canada. The tax team has more than 1,000 professionals working in a variety of industries including energy, financial services, mining and private equity. Tony Swiderski, Angela Yu and Jodi Kelleher acted for a client in connection ... [more]

PwC

PwC's international tax partner Jim Wilson in the Toronto office of Wilson & Partners, a law firm affiliated with PwC, is praised by competitors for being an excellent tax lawyer with expertise in M&A and capital markets. Richard Marcovitz is recognised ... [more]

Bennett Jones advises Asian clients on inbound investments and M&A activity with services to large, mid-size and small capitalisation clients. International clients include Apache Canada and other large US oil and gas companies acquiring energy assets ... [more]

Felesky Flynn has offices in Calgary and Edmonton. John Burghardt is noted as a strong M&A specialist by peers. The tax team is making its presence felt in the market, according to a group of tax lawyers.

Bill Innes and David Spiro of Fraser Milner Casgrain are highly respected tax litigators. The firm has a reputation in the market as one of the strongest tax litigation firms in Canada.

Torys is known for its transactional work and the practice continued in this tradition when partners Corrado Cardarelli and Richard Johnson advised in the $3.2 billion acquisition by Scotiabank of Dundee Wealth in February 2011. The transaction was designed ... [more]

Borden Ladner Gervais has offices in six locations throughout Canada. While the Vancouver office tends to concentrate on Asian funds flowing into Canada, the tax team in Montréal serves as a gateway to support international transactions outside Asia. ... [more]

Burnet Duckworth & Palmer has a small tax group of 11 tax lawyers. Calgary partner John Brussa, is known for his corporate tax work.

Fasken Martineau's tax practice partners William Bies, David Fox and Christopher Steeves advised Franco-Nevada Corporation on the $650 million acquisition of all of the common shares of Gold Wheaton Gold Corporation that it did not already own, pursuant ... [more]

The Gowlings - Taxand tax team has strengthened its practice with the additions of partners Marc-André Godard and Sandra Mah from McCarthy Tetrault in September and October 2010, as well as Jim Wilson, who joined from the Canada Revenue Agency (CRA) ... [more]

Norton Rose OR was called Ogilvy Renault until June 1 2011, when that firm joined the Norton Rose Group. Senior partner Wilfrid Lefebvre is noted for his tax controversy and litigation expertise.

Partners Michael Colborne and Michael McLaren of Thorsteinssons have acted in many high profile M&A transactions in the past year, including the $3.6 billion acquisition of Andean Resources by Goldcorp in December 2010. The niche tax firm has offices ... [more]

The advisers at Grant Thornton cover all areas of tax advice. The international tax group has a number of subspecialties within it, including specific advice for doing business in China, India, and Latin America. Professionals in these groups have extensive ... [more]

Millar Kreklewetz's founding partners, Millar Kreklewetz, Jack Millar and Robert Kreklewetz are praised by competitors for their advanced indirect tax skills.

Jennifer Rhee of RSM Richter's tax group is commended for her advanced transfer pricing skills. The firm is still "a leader in the small cap market," says advisers. Jerry Wise is recommended for his "quality tax work."

Stewart McKelvey's tax group works closely with the firm's other practice groups to provide its clients with imaginative practical solutions. The firm regularly advises client in personal and corporate tax planning matters including business structures, ... [more]

See also

Canada
North America

Firm contact details