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Proposed hybrid mismatch arrangement rules

Tax Alert 2026 No. 09, 23 February 2026

On 29 January 2026, the Department of Finance released two packages of draft legislative proposals for public comment. The proposals implement certain measures announced in the 2025 federal budget, as well as other previously announced measures and new technical amendments, including the much-anticipated second package of hybrid mismatch arrangement rules.

In this Tax Alert, we provide an overview of certain proposals outlined in the second package of hybrid mismatch rules, which is intended to implement the recommendations of the report under Action 2 of the OECD/G20 Base Erosion and Profit Shifting project, titled Neutralising the Effects of Hybrid Mismatch Arrangements.

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Previous issues

British Columbia Budget 2026

BC Finance Minister Brenda Bailey tabled the province’s fiscal 2026 budget on 17 February 2026.

Northwest Territories 2026 budget

Northwest Territories Finance Minister Caroline Wawzonek tabled the territory’s 2026 budget on 5 February 2026.

Federal procurement thresholds for free trade agreements updated

The Government of Canada published Contracting Policy Notice 2025-8 Trade Agreements: Thresholds Update, on 5 January 2026.

Draft legislative proposals released for Budget 2025 and other previously announced measures

On 29 January 2026, the Department of Finance released two packages of draft legislative proposals for public comment. The draft legislative proposals implement certain measures announced in the 2025 federal budget (Budget 2025), as well as other previously announced measures and new technical amendments.

CBSA issues its 2026 trade compliance verification list update

The Canada Border Services Agency (CBSA) released its January 2026 update to the trade compliance verification priorities list.

Canada provides guidance for the steel derivative goods surtax and relief for certain steel goods

On 24 December 2025, the Canada Border Services Agency published Customs Notice 25-33, Steel Derivative Goods Surtax Order.

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