As published in the Canadian Tax Foundation’s Perspectives on Tax Law & Policy


The COVID-19 pandemic has had a devastating impact on economies around the world. Unemployment has soared, while trade has slowed and investment has plummeted. As economies slowly begin to reopen and put in place recovery plans, the focus of governments will turn to job creation and attracting investment.

Further complicating the economic environment is a rise in protectionism, with countries re-examining global supply chains and implementing beggar-thy-neighbour policies in an attempt to protect and create jobs at home. Canada must be prepared for this new global economic reality and have a plan in place to fight for job-creating investment.

While there is little Canada can do to combat protectionism, we have the ability to create a more competitive investment environment. One of the keys to achieving this is to review and then redesign the tax system in a way that emphasizes attracting investment.

Calls for a review of the tax system were growing loud well before the pandemic. The Standing Senate Committee on National Finance recommended that Canada undertake a comprehensive independent review of the tax system, with the goal of reducing complexity, ensuring economic competitiveness, and enhancing overall fairness. In light of the economic devastation wrought by COVID-19, we have little choice but to act on this recommendation, with a focus on re-evaluating Canada’s global tax competitiveness.

The Great Lockdown

Prior to COVID-19, advanced countries around the world faced the prospect of slower growth, a result of demographic forces and weak productivity growth. In addition to these challenges, the Canadian economy faced heightened trade uncertainty, ongoing tensions with China, crippling rail blockades, and a deteriorating investment climate caused by regulatory uncertainty.

According to the Parliamentary Budget Officer, the Canadian economy is now expected to shrink by a previously unthinkable 12 percent in 2020. Facing this extremely dire outlook, Canada must find new ways to compete on the world stage, grow the economy, and create jobs. Attracting global investment to Canada through a more competitive tax environment is one important way to achieve this.

Canada’s Investment Record

While global foreign direct investment (FDI) stocks have increased dramatically over the past 25 years, Canada’s share of global investment has been declining. In 2018, Canada’s share of total world inward investment stocks fell to 2.8 percent, the lowest level in nearly 20 years. Meanwhile, countries with more competitive corporate tax systems, such as Ireland and Switzerland, have witnessed an increasing share of global inward investment stocks.

Source: UNCTAD STAT, 2020

Of the world’s 500 largest companies, only 13 are headquartered in Canada, according to Fortune 500. In 2019, Canada ranked ninth as a location for the global headquarters of the world’s largest corporations, behind China, the United States, Japan, France, Germany, the United Kingdom, South Korea, and Switzerland.

Comparing Canada with the top 10 Global 500 company locations on the basis of GDP tells a similar story. Canada has 7.6 Global 500 company headquarters per trillion dollars of GDP, a lower ratio than in smaller economies with more competitive corporate tax systems, including Switzerland and the Netherlands.

Source: Fortune 500, World Bank

The United Nations Conference on Trade and Development (UNCTAD) identifies the main determinants of head-office location as international accessibility; a skilled workforce; a high quality of life with which to attract international staff; low corporate and personal taxes; ­­­excellent information and communication technology infrastructure; well-developed business support services (legal, accounting, and public relations); low risk (with respect to crime, exchange rates, and regulatory and tax changes); and proximity to customers.

Canada excels in many of these areas and has a natural geographic advantage, given its proximity to the United States. But we could do better in our efforts to achieve a more efficient tax regime. In fact, tax rates and the complexity of tax regulations are routinely cited by the World Economic Forum as among of the most problematic factors when it comes to doing business in Canada.

In a rapidly shifting global economic environment, Canada must explore tax changes that would attract investment. A competitive tax regime, combined with Canada’s existing advantages (for example, trade agreements, time zone, business culture, language, immigration policy, proximity to the United States, and public health care), could make Canada the premier location for global headquarters.

Attracting more large companies and more global headquarters would create significant benefits for Canadians. Large companies typically employ highly skilled and well-paid employees. According to the Business Council of Canada’s Sixth Annual Canadian Total Tax Contribution Survey, which surveys the tax contributions of Canada’s largest companies, the average wage paid by survey participants is $67,000, 32 percent higher than the national average.

In addition, large companies support an ecosystem of businesses in the communities where they are located. They purchase high-value services from consultants, lawyers, financial services providers, and information technology companies. They also support small and medium-sized enterprises (SMEs) that form an integral part of the corporate supply chain.

On the basis of data collected from 50 of Canada’s largest businesses, a study by the Centre for Digital Entrepreneurship and Economic Performance found that these large companies often serve as crucial “anchor customers” for SMEs, relying on Canadian SMEs, on average, for more than one-third of their input purchases. Collectively, the 50 companies that took part in the study purchase $37 billion in goods and services annually from 158,550 SMEs across the country.

If the purchasing behaviour of those 50 companies reflects the behaviour of the broader population of 350 large Canadian firms (those with at least $1 billion in revenues), it would suggest that large companies in Canada buy more than $260 billion in inputs each year from more than 1 million SMEs.

Restoring Canada’s Corporate Tax Advantage

Canada has made significant progress in lowering its statutory cit rate without significant negative implications for revenue generation. Since the 1970s, when the federal cit rate was nearly 40 percent, steady reductions in the rate have had virtually no impact on federal cit revenue as a share of GDP. As companies have found it more attractive to earn profits in Canada because of the lower rate, the rate reduction has been offset by an expanding tax base.

Source: Department of Finance

Despite lowering the federal cit to 15 percent, Canada still lags behind its competitors in terms of tax competitiveness. Canada has the 10th-highest combined federal-provincial cit rate in the OECD, with a combined rate of 26 per cent, well above the OECD average of 23 percent, according to OECD data. When dividend withholding tax is taken into account, Canada’s combined cit rate is among the highest in the OECD.

Source: OECD, Corporate Income Tax Rates, 2020

As a result of other countries’ efforts to attract global investment (such as the UK announcement that it would reduce its CIT rate to 19 percent and the us move to reduce its federal CIT rate to 21 percent), the gap between Canada’s CIT rate and our competitors’ rates is growing.

Source: OECD, Corporate Income Tax Rates, 2020


The COVID-19 pandemic and the ensuing lockdown have had a dire impact on the Canadian economy and government balance sheets. The fiscal impact of the pandemic has been devastating; the federal deficit is expected to reach $252.1 billion in 2020-21. The federal debt could approach $1 trillion, if the pandemic lasts longer than anticipated and support programs need to be extended.

Austerity measures will not be sufficient to lower the deficit and return to a pre-crisis debt-to-GDP ratio of 30 percent. The best way to unwind the extraordinary support programs and repair the federal balance sheet is to grow the economy. This can be achieved only through aggressive efforts to attract and encourage job-creating investment.

Restoring our corporate tax advantage over the United States would be a good start. A 2018 study by PwC Canada found that us tax reform eliminated one of Canada’s main competitive advantages and had a significant negative impact on capital-intensive sectors in Canada.

The introduction of the accelerated investment incentive in the 2018 fall economic statement was a helpful step, but Canada needs to do more to remain competitive with the United States. This effort could include gradually reducing the combined federal-provincial statutory cit rate to 20 percent, enhancing Canada’s system of tax credits for business spending on research and development, and introducing a patent box for innovative companies that locate their research and development operations in Canada.

Canada will not be alone in trying to attract investment and spur growth. We must be prepared to compete with other jurisdictions around the world. If our natural advantages as a location for business investment are combined with a world-class corporate tax regime, Canada could become the premier destination in the world for investment, headquarter locations, and, ultimately, job creation.

Brian Kingston is the Vice President of Policy, International and Fiscal