About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline

1 1 (January 6, 2025)

handle is hein.crs/goverxh0001 and id is 1 raw text is: 















Canada's Digital Services Tax Act:

Issues Facing Congress



Updated January 6, 2025

In June 2024, the Canadian government enacted Bill C-59, which included a 3% digital services tax
(DST)-retroactive to January 1, 2022-on certain revenue of large digital services providers active in,
for example, online marketplaces, online advertising, social media platforms, and the sale or licensing of
user data. Some Members of Congress have expressed concerns that Canada's DST discriminates against
U.S. firms and have urged the Biden Administration to consider retaliatory trade measures.
The United States is home to several ofthe world's largest digital services providers (e.g., Meta, Netflix),
which are a large and fast-growing segment of the U.S. economy, with $213 billion of revenue and
278,000 workers in 2024. Revenue for social networking sites is expected to increase by 18% from 2024
to 2025. Digital services providers are to register with the Canadian Revenue Agency by January 31,
2025, and make their first tax payments by June 30, 2025.

Background and Scope of the DST

In addition to Canada, 18 other countries have implemented DSTs. DSTs differ from existing corporate
income taxes on multinationals. DSTs are taxes on revenue derived from the sale of digital goods and
services in the jurisdiction imposing the tax. The existing global tax regime taxes multinationals' profits
(revenue adjusted for expenses) in the country in which the income is earned and, in some instances, the
country in which a parent firm is headquartered. Proposals for DSTs are increasingly common in part
because they allow governments to tax multinationals providing digital services even ifthe firm does not
generate income through the ownership of assets in their jurisdiction.
In October 2021, members of the Organization for Economic Co-operation and Development
(OECD)/Group  of 20 (G20) Inclusive Framework, including the United States and Canada, agreed on a
plan to update the global tax system to address profit shifting and develop an international digital tax
framework. In July 2023, 138 out of 145 Framework members agreed to hold off on imposing DSTs until
at least 2025 to allow for additional negotiations. Canada objected, stating that it would not support a
DST  moratorium without a firm and binding timeline for Framework implementation.
Canada's DST entered into force on June 28, 2024, and applies to foreign and Canadian digital services
providers that earn (1) total annual revenue from all sources of 750 million euros ($815 million USD) or

                                                                 Congressional Research Service
                                                                   https://crsreports.congress.gov
                                                                                       IN12399

CRS INSIGHT
Prepared for Members and
Committees of Congress

What Is HeinOnline?

HeinOnline is a subscription-based resource containing thousands of academic and legal journals from inception; complete coverage of government documents such as U.S. Statutes at Large, U.S. Code, Federal Register, Code of Federal Regulations, U.S. Reports, and much more. Documents are image-based, fully searchable PDFs with the authority of print combined with the accessibility of a user-friendly and powerful database. For more information, request a quote or trial for your organization below.



Short-term subscription options include 24 hours, 48 hours, or 1 week to HeinOnline.

Already a HeinOnline Subscriber?

profiles profiles most