Changes to the T1134 Filing Deadline

Multinational corporations that are required to file an information return in prescribed form (T1134) in respect of their foreign affiliates will soon see a tightened filing deadline. The Department of Finance released a Notice of Ways and Means Motion on October 25, 2018 that includes a provision to shorten the deadline for corporations to file their T1134 forms to 12 months (from 15 months) after their year-end for taxation years beginning after 2019, and to 10 months for taxation years beginning after 2020. The 2018 federal budget had proposed to shorten this filing deadline to six months (from 15 months) after the taxpayer’s year-end. This change was initially intended to align the information return filing deadline with the taxpayer’s income tax return filing deadline. Despite receiving submissions that the shortening of the filing deadline should be reversed in light of the significant compliance challenges it will place on many taxpayers[1], the Department of Finance appears only willing to provide limited relief. Note that the filing deadline for country-by-country reports of a multinational enterprise group is 12 months.

[1] See the May 18, 2018 Joint Committee Submission re Reporting Requirements in Respect of Foreign Affiliates.

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