SIMA urges government to adjust draft tax legislation and give industry more time to implement
September 12, 2025 – Toronto – The Securities and Investment Management Association (SIMA) is urging the government to make changes to its latest proposed tax legislation, including requesting later implementation dates.
On August 15, 2025, the Department of Finance released draft legislative proposals for consultation, aimed at implementing a number of previously announced and other tax measures. These proposals include the adoption of the Organization for Economic Co-operation and Development’s (OECD) Crypto-Asset Reporting Framework (CARF) and implementation of amendments to Part XIX Common Reporting Standard (CRS) of the Income Tax Act (Canada). The measures are proposed to take effect on January 1, 2026, with limited transitional relief provisions.
In our draft response to Finance, SIMA says the implementation timeline outlined in the draft legislation does not offer the industry a realistic or practical pathway to achieve full—or even substantial—compliance. The effective implementation of CARF and the proposed amendments to CRS will require significant operational, technical, and compliance system changes. These changes are far more extensive than what could reasonably be accomplished within a three-to-four-month timeframe. Accordingly, SIMA recommends that the effective date be deferred, along with the following requests:
For CRS 2.0, we ask that:
- the implementation be deferred to January 1, 2027, with first reporting under the new requirements due in May 2028
- the transitional relief apply to all new data elements and be extended to reporting periods ending before 2029
- all passive non-financial entity accounts opened prior to the implementation date be grandfathered
- the proposed anti-avoidance rule in section 280 expressly limit reporting financial institution obligations to actual knowledge of avoidance arrangements
For CARF, we ask that:
- the implementation be deferred to January 1, 2028, with first reporting due in May 2029
- the transitional relief be extended to reporting periods ending before 2030
About SIMA
The Securities and Investment Management Association empowers Canada’s investment industry. The association is the leading voice for the securities and investment management industry, which oversees approximately $4 trillion in assets for over 20 million investors and the Canadian capital markets. Our members—including investment fund managers, investment and mutual fund dealers, capital markets participants, and professional service providers—are committed to creating a resilient, innovative investment sector that fuels long-term economic growth and creates opportunities for all Canadians.
For more information
Christine Harminc
Director, Communications and Public Affairs
charminc@sima-amvi.ca
416-309-2313
