Any taxpayer who carries out a specified transaction (or who is a member of a partnership that carries out a specified transaction) whose form and substance of the facts specific to the taxpayer or partnership are significantly similar to the form and substance of the facts of a transaction determined by the Minister and published in the Gazette officielle du Québec must disclose the transaction. The disclosure is made using form TP-1079.OD-V, Mandatory Disclosure of a Specified Transaction or Preventive Disclosure.

An adviser or promoter who commercializes or promotes a determined transaction must also disclose the transaction by completing form TP-1079.CP-V, Mandatory Disclosure of Tax Planning by an Adviser or Promoter.

However, taxpayers, advisers and promoters are not required to file a disclosure form for any transaction that Revenu Québec has identified as an excluded transaction.

On June 17, 2025, a new excluded transaction under determined transaction 3, “Multiplication of the Capital Gains Deduction,” was identified and published on our website. The transaction is as follows:

“The sale of a share referred to in subparagraph (b) of the first paragraph of the description of the determined transaction above by a vendor referred to in subparagraph (a) of the first paragraph of the description of the determined transaction above and for which the contract sets out any of the following terms, if the vendor and purchaser are dealing at arm's length or if the agreed terms for the amount owing are such that persons not dealing at arm's length would have agreed to them at the time they were accepted:

• a balance of sale;
• an earn-out clause;
• a reverse earn-out clause.

If sections 517.5.3 and following of the Act apply to the sale, the vendor and purchaser are deemed to be dealing at arm's length for the purposes of this exclusion.”

For a list of determined transactions, the deadline for making a mandatory disclosure or more information, see Determined Transactions.

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