Tax Insights: Voluntary Disclosures Program in jeopardy

Issue 2016-59

On December 8, 2016, the Canada Revenue Agency released “Report on the Voluntary Disclosures Program” (VDP), which sets out recommendations of the Offshore Compliance Advisory Committee. The report states that the 11 recommendations are designed to “enhance and improve” the VDP. 

If implemented, the recommendations would radically alter the VDP – effectively the current program would no longer exist. In particular:

  • the program would be increasingly used as a tool to conduct more audits 
  • the result of a disclosure would be more discretionary and less certain
  • the increased discretion and uncertainty would lead to more tax disputes

If you are contemplating a voluntary disclosure you may want to act soon. The VDP will change significantly if the recommendations are implemented. We expect that the VDP’s value to taxpayers that are inadvertently, or intentionally, non-compliant would be reduced and that this would decrease the number of disclosures.

Read this Tax Insights for more information.


{{contentList.dataService.numberHits}} {{contentList.dataService.numberHits == 1 ? 'result' : 'results'}}

Contact us

Marc Vanasse

National Tax Dispute Resolution Leader, PwC Canada

Tel: +1 613 782 2988

Bill Nakano

Senior Manager, PwC Canada

Tel: +1 780 441 6819

Patrick Lindsay

Partner, PwC Law LLP

Tel: +1 403 509 6386

Dan Rivet

Senior Tax Adviser, PwC Canada

Tel: +1 613 782 2976

Follow PwC Canada