The latest iteration of the Canadian federal government's amendments to its General Anti-Avoidance Rule (GAAR), introduced to parliament on 30 November 2023 in Bill C-59, alters the new economic substance test to state that 'significantly lacking' economic substance is an 'important consideration that tends to indicate' there has been a misuse or abuse. It also increases the originally proposed penalties to 25 per cent of the total value of both the additional tax payable and reduced tax credits. Penalty provisions will only apply to transactions occurring on or after the later of January 1 2024 and the day on which Bill C-59 receives royal assent.
News Source：【Thorsteinssons 2024/01/09】