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Tax Alert 2026 No. 02, 12 January 2026
On 5 January 2026, the OECD released its highly anticipated Side-by-Side package in the form of new administrative guidance published in respect of the Global Anti-Base Erosion Model Rules approved by the OECD/G20 BEPS Inclusive Framework.
The Side-by-Side package includes an extension of the Transitional Country-by-Country Report Safe Harbour as well as four new permanent safe harbours in the form of a Simplified Effective Tax Rate Safe Harbour, a Substance-based Tax Incentives Safe Harbour, the Side-by-Side Safe Harbour and an Ultimate Parent Entity Safe Harbour.
In this Tax Alert, we provide a brief overview of certain measures included in the Side-by-Side package and the impact it may have on Canadian taxpayers by way of future anticipated changes in the Global Minimum Tax Act (GMTA) to align with these new measures. We also briefly summarize other recent Canadian developments with respect to the GMTA.
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Issue No. 02, 12 January 2026
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Previous issues
Reversal of longstanding position with respect to the GST/HST status of trailing commissions
In a recent GST/HST interpretation provided to an industry group, the Canada Revenue Agency indicated that it will reverse its longstanding administrative position on the GST/HST status of trailing commissions and adopt the position that trailing commissions are taxable for GST/HST purposes, effective 1 July 2026.
Information released with respect to measures announced to protect Canada’s steel industry
On 12 December 2025, the Minister of Finance and National Revenue announced various measures to support the Canadian steel industry. More specifically, these measures will reduce tariff rate quotas on certain steel imports and impose a new global tariff on a specific list of steel-derivative products.
Accelerated CCA and other immediate expensing measures
On 18 November 2025, the federal government tabled Bill C-15, Budget 2025 Implementation Act, No. 1, which included several measures related to accelerated capital cost allowance (CCA) and other immediate expensing measures.
OECD Commentary 2025: Lower risk for remote work — Is it time to rethink your policy?
On 19 November 2025, the OECD released an update to the OECD Model Tax Convention and its Commentary. In particular, the Commentary on Article 5 (Permanent Establishment) includes additional guidance on cross-border remote work.
Valuation for Duty Regulations, take two: CBSA invites feedback on revisions to 2023 proposals
On 3 December 2025, the Canada Border Services Agency (CBSA) announced it is requesting feedback on revisions to proposed amendments to the Valuation for Duty Regulations, which were published in 2023.
Canada announces new measures for steel imports
On 26 November 2025, Prime Minister Mark Carney announced that Canada will reduce tariff rate quotas on certain steel imports and impose a new global tariff on a specific list of steel-derivative products.
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