Who files Form T2 Schedule 25?

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Answer

Canadian corporations with foreign affiliates, filed with the corporate return. The obligation is decided by facts rather than by tax owing, which is why a nil position does not remove it.

The rule on who files

Canadian corporations with foreign affiliates, filed with the corporate return.

The team reviewing a file together at a desk

Where the general answer is wrong

It is the flag that leads to the full foreign affiliate reporting package. Filing the schedule and not the affiliate return, or the reverse, is an inconsistency the CRA sees immediately.

Who files Form T2 Schedule 25?
ItemAmount
Cost of the propertyC$320,000
Value on the departure dayC$467,200
Accrued gain treated as realisedC$147,200
Amount assumed to enter incomeC$73,600
Tax at an assumed 33%C$24,288

C$24,288 becomes payable in a year with no sale and no cash. That is what makes the departure date a planning variable: losses realised before it, an election to defer payment against security, and defensible valuations for anything private all change this number.

The figures here are an illustration, not an engagement: amounts are picked so the mechanism is easy to follow, and every rate or threshold is an assumption of the example. Before anything is filed for you, each one is confirmed with the issuing authority for your own tax year.

Where to go from here

The full treatment — who it binds, the deadline, the penalty and the fixed fee — is on T2 Schedule 25 — foreign affiliates. Ask before the move rather than after it, because most of the useful options expire on the date.

Checked and signed off for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. Written as general guidance, not as a recommendation for your situation. Talk it through with us before acting on it.

Who needs to file FATCA, in practice

People reach this page searching for who needs to file FATCA. It is covered here as it applies to Form T2 Schedule 25 — who it applies to, what has to be filed, and what it costs, at a fixed fee agreed before the work starts.

What these engagements turn on

Case study 1

Shareholding chart rebuilt to identify the foreign affiliates

A corporation knew it had foreign holdings and did not know precisely what they were, because the group had grown by acquisition over a decade and no single document described it. We collected the share registers and the acquisition papers for each entity, drew the chart with the interest held at each level, and agreed it with the directors before anything was drafted. The engagement produced an agreed group chart, a schedule built from it, and a list of the entities whose paperwork could not be located, so the gaps were visible rather than silently omitted.

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Case study 2

Dormant foreign subsidiary added to the corporate schedule

A company held a subsidiary abroad that had traded briefly and then stopped. Because it appeared in no accounts other than as an investment, it had been left off the corporate schedule for several years. We confirmed the holding from the register, established that the entity had never been wound up, and prepared corrected schedules for the open years so the affiliate is described consistently throughout. The engagement produced amended filings, a decision point put to the directors on whether to keep the entity at all, and a note explaining why a dormant company is still reportable.

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Case study 3

Personal foreign shares kept off the corporation's schedule

A director assumed that shares he held personally in an overseas company belonged on the company's schedule, because the company had paid for part of the investment. We traced the funding, established who actually held the interest, and set out which filings each holding belonged in — the corporation's schedule for what the corporation held, his own reporting for what he held. The engagement produced a corrected schedule, a written analysis of the funding trail, and a recommendation on tidying the registration so the question does not have to be re-answered every year.

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Case study 4

Affiliate interest traced through an intermediate holding company

A group held its operating company abroad through a second foreign entity, and the corporate schedule named only the company at the bottom. We mapped the chain, established the interest held at each level and the dates on which each was acquired, and rewrote the schedule so every affiliate in the chain is identified rather than only the one the directors thought of as the business. The engagement produced a schedule that matches the structure, and a group chart the company now updates whenever an entity is added or removed.

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Case study 5

Schedule reconciled with the foreign affiliate reporting package

A corporation had completed its foreign affiliate reporting and its corporate schedule in different offices, from different lists, and the two did not name the same companies. We built a single list of affiliates from the registers, mapped each entry to both filings, and identified where each had gone wrong. The engagement produced a consistent set of filings for the year, one agreed source list that both pieces of work are now driven from, and a short procedure so the two are prepared together rather than in parallel.

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Case study 6

Mid-year disposal of a foreign subsidiary written up for the file

A group sold an overseas subsidiary part-way through its year and assumed the holding would simply drop out of the corporate schedule. We established what was held and for how long, recorded the date and the terms of the disposal, and prepared the schedule with the position as it stood during the year rather than as it stood at the year end. The engagement produced a filed schedule that explains the change in the group, and a documented disposal that answers the obvious question about why an affiliate appears in one year and not the next.

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Case study 7

A Foreign Subsidiary That Nobody Had Been Reporting

Owning a company abroad triggers an information return separate from the corporate return, with its own penalty. The work is the surplus and income computations behind it, which also determine how a future dividend is taxed on the way home.

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Case study 8

A Foreign Affiliate Return Filed Years Late

The reporting obligation on a company held abroad runs separately from the corporate return and carries its own exposure. The work is reconstructing the surplus position across the open years before any filing goes in.

Read how this one runs

All case studies — every published engagement in one place.

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Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

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Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.

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Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

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Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.

India Tax for NRIs & Returning Residents

The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.

Canadian Tax with a Foreign Element

Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

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A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

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Cross-border tax for sellers shipping worldwide: marketplace withholding, foreign registrations and inventory nexus handled before they become audits.

Marketplaces withhold, remit and report in their own right, so the tax position of a single sale is decided by where the stock sat, where the buyer was and which platform collected — not by where the company is registered. We reconcile the platform's own filings against the returns before either is submitted.

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The follow-up questions on Form T2 Schedule 25

Who has to file Form T2 Schedule 25?

A Canadian corporation with foreign affiliates files Schedule 25, and it files it with the corporate return rather than separately. The schedule identifies the foreign affiliates and sets out the Canadian corporation's interest in each. Two things follow from that. The obligation belongs to the corporation, so shares held personally by a shareholder are not what this schedule describes. And the schedule is a statement about holdings rather than about profit, so an affiliate that earned nothing in the year is still an affiliate. In practice the work of completing it is the work of establishing the group's shareholdings accurately; once that is settled, the schedule itself is short.

Do we file Schedule 25 if the foreign subsidiary is dormant?

Yes. The schedule reports the interest the Canadian corporation holds in its foreign affiliates, so it follows the shareholding rather than the activity. A dormant subsidiary that files nothing in its own country and appears nowhere in the Canadian accounts other than as an investment on the balance sheet is exactly the holding that gets forgotten, and it is reportable all the same. Dormant entities are also where inconsistency creeps in, because the holding is described one way in the year it was acquired and differently once nobody can remember why it exists. We check the register before the schedule is drafted.

Does filing Schedule 25 mean we owe more reporting on the affiliate?

Usually, yes — and that is the point of it. The schedule is the flag that leads to the full foreign affiliate reporting package, so completing it is the start of the work rather than the end. The error we see most often is a group that completes one and not the other: the schedule names an affiliate the affiliate reporting does not cover, or the affiliate reporting describes a company the schedule never mentioned. Those are read against each other, and the inconsistency is visible immediately. We settle the list of affiliates once, then drive both the schedule and the affiliate reporting from that single list.

Our foreign shares are held personally — does Schedule 25 apply?

Not to the corporation. Schedule 25 is a corporate schedule that travels with the corporate return and describes the corporation's own interests in foreign affiliates. Shares a shareholder holds personally are that person's holding, and they are dealt with in their own filings rather than on the company's schedule. The complication is that groups are rarely as tidy as the question assumes. Shares are transferred into the company and the paperwork follows later, or the company pays for a holding registered in a director's name. What matters is who actually holds the interest, so the register and the funding trail are worth establishing before the schedule is prepared.

We hold the foreign company through another company — who reports it?

The answer turns on the chain of interests rather than on the entity at the bottom of it. Schedule 25 asks what interest the Canadian corporation has in foreign affiliates, and an interest held through an intermediate company is still an interest that has to be identified and described. In a group of any size this is a mapping exercise: the shareholdings, the proportion held at each level and any changes during the year, drawn out once and agreed before anything is drafted. Groups that skip the mapping usually produce a schedule that is right about the companies they remembered and silent about the ones they did not.

We sold the foreign subsidiary during the year — is it reported?

That is settled on the facts of the year rather than on the position at the year end. An interest the corporation held during the year is a fact about the year, so it is not safe to assume a holding disposed of before the year end simply disappears from the return. Where a holding existed and was sold, we set out the position as it stood, record the date and the terms of the disposal, and keep the supporting documents with the file, so the change in the group is explained rather than inferred from an affiliate appearing one year and vanishing the next.

What is double taxation in a corporation?

That is the economic form: the company pays tax on its profit, then the shareholder pays tax again on the dividend distributed out of that same after-tax profit. Domestic systems soften it with dividend credits or reduced rates on distributions; across borders it is compounded by withholding tax in the paying country. Which relief applies turns on the entity type and the treaty article covering dividends. See repatriating profits.

Does a remote employee create a permanent establishment?

It can. One employee working from home in another country may be enough where the arrangement gives the company a fixed place at its disposal, or where that person habitually concludes contracts. Seniority and function matter more than headcount: a salesperson closing deals is a far greater risk than a developer. The exposure is corporate tax and payroll registration in that country, which is why it is worth testing before the hire rather than after. See PE risk review.

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