Preparing T106 information returns - Tips and Traps

The course offers an overview of completing T106 - Information Return of Non-Arm's Length Transactions with Non-Residents (T106). The course will discuss the possible traps and how to identify tax issues with completing T106. The course provides a practical perspective on filing T106 forms and what are some of the red flags that can raise a CRA audit. The course also includes walk through of T106 summary and slip.

5 Jun 2020, 9:00 AM

1.5 CPD hours


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Course Description


  • Overview of Form T106 filings requirements and obligations
  • Completing T106 summary form – Section I, II & III
  • Completing T106 slips – Part I, II, III, IV, V & VI
  • How to identify tax issues and exposures when preparing/reviewing T106
  • Traps and Inherent risks with cross-border inter-company transactions
    • Upstream loan tax implications and Foreign affiliate dumping
    • Thin capitalization rules and back-to-back loan rules
    • Shareholder loan issue and deemed dividend
    • Withholding tax
  • Payments to non-residents and withholding tax implications
  • Transfer pricing issues - what to look for in a T106?
  • Identify CRA audit red flags when preparing T106?


This course is designed for tax professionals who would like an overview of Canada’s international tax reporting, compliance and filing of T106. The course will benefit people who advise corporations on cross-border taxation; provide services to the cross-border client; work at a Canadian or foreign multinational company as a tax manager or director.

Course Walkthrough

  • Presentation
  • Recording
  • Certificate: Preparing T106 information returns - Tips and Traps
  • Feedback / comments

About the Instructor(s)

Picture of Affan Khalid
Affan Khalid

Affan Khalid, CPA, CA is a Senior Manager in International Tax at MNP LLP. He has over 15 years of experience and provides international tax advice to Canadian and foreign-based multi-nationals with a focus on inbound and outbound tax planning and structuring, including financing structures, acquisitions and dispositions, tax due diligence, reorganizations and cash repatriation strategies. He obtained his BBA from the University of Toronto and have completed In-depth International course and In-depth tax program.

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