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Tax Alert 2026 No. 03, 13 January 2026
On 24 December 2025, the Canada Border Services Agency published Customs Notice 25-33, Steel Derivative Goods Surtax Order. This notice provides administrative guidance for the Steel Derivative Goods Surtax Order, which imposes a 25% surtax on certain steel derivative goods imported into Canada on or after 26 December 2025.
The surtax was one of several measures announced by Prime Minister Mark Carney on 26 November 2025 to support Canada’s steel industry.
As well, the Surtax on Imports of Certain Steel Goods Remission Order, 2025, was published in Part II of the Canada Gazette on 31 December 2025. This order provides remission for the 50% surtax imposed on certain imported steel goods for which there are no identified domestically produced alternatives.
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Issue No. 03, 13 January 2026
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Previous issues
Initial insights regarding the OECD Side-by-Side administrative guidance on Canadian taxpayers
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.
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.
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