Welcome to the April issue of Blakes Competitive Edge, a monthly publication of the Blakes Competition, Antitrust & Foreign Investment group. Blakes Competitive Edge provides an overview of recent developments in Canadian competition and foreign investment law, including updates on enforcement activity by the Canadian Competition Bureau (Bureau), recent initiatives and key trends.
Key Highlights
- Merger review activity in 2025 has slightly increased compared to the last two years, with the Bureau completing 54 merger reviews through the end of March 2025. This is a 24.1% increase over the number of merger reviews completed through the end of March 2024 (41) and a 20.4% increase over the number of merger reviews completed through the end of March 2023 (43). Notably, the percentage of merger reviews resulting in a No Action Letter has increased, from 51% through the end of March 2024 and 53% through the end of December 2024, to 65% through the end of March 2025.
- Anita Anand is appointed as Canada's Minister of Innovation, Science and Industry and Steven Guilbeault is appointed as Minister of Canadian Culture and Identity, Parks Canada.
- The Bureau files a reply in its abuse of dominance application against Google.
- The Bureau increases its filing fee for merger reviews.
Competition Act
Merger Monitor
March 1 – March 31, 2025 Highlights
- 16 merger reviews announced, 15 merger reviews completed
- Primary industries of completed reviews: real estate and rental and leasing (27%); finance and insurance (20%); transportation and warehousing (20%); information and cultural industries (13%)
- Nine transactions received an Advanced Ruling Certificate (60%); six transactions received a No Action Letter (40%)
January – March 31, 2025 Highlights
- 53 merger reviews announced, 54 merger reviews completed
- Primary industries of completed reviews: real estate and rental and leasing (24%); finance and insurance (15%); transportation and warehousing (11%); manufacturing (11%); wholesale trade (11%); information and cultural industries (7%)
- 35 transactions received a No Action Letter (65%); 17 transactions received an Advance Ruling Certificate (31%); one transaction was abandoned by the merging parties; one transaction was resolved through other means
Merger Reviews Completed Year to Date Through March 31, 2025, by Primary Industry
Enforcement Activity
Bureau Replies in its Abuse of Dominance Application Against Google
- On March 28, 2025, the Commissioner of Competition filed a reply to Google Canada and Google LLC (Google) regarding pleadings filed by Google on February 14, 2025. Google's pleadings were in response to the Bureau's November 2024 application, which alleged that Google abused its dominant position through anti-competitive practices related to its advertising technology tools. In its reply, the Bureau contends that: (1) Google improperly combined distinct and "non-substitutable" advertising technology services in its assertion that there is a single, two-sided product market for advertising technology tools; (2) Google has and asserts dominance in the Published Ad Server and Advertiser Ad Network markets through anti-competitive conduct; (3) Google's anti-competitive conduct had, is having and is likely to have the effect of preventing and lessening competition in the Bureau's proposed relevant product markets; and (4) contrary to Google's assertion, the administrative monetary penalty and divestitures sought by the Bureau are constitutional and within the Competition Tribunal's jurisdiction. For more details on the Bureau's application against Google, see Blakes Competitive Edge" December 2024 and March 2025 Updates.
Settlement Reached for Saguenay-Lac-Saint-Jean, Quebec Territory Allocation Scheme
- On March 20, 2025, the Bureau announced that Pavex Ltd. had agreed to pay a settlement of C$150,000 for entering into an illegal agreement with competitors. The alleged conduct involved paving contracts in the Saguenay-Lac-Saint-Jean, Quebec region between 2008 and 2010, awarded by the Ministère des Transports du Québec. In 2023, Inter-Cité Construction Ltée was also required to pay a settlement of C$150,000 in connection with the conduct.
Non-Enforcement Activity
Bureau Increases Filing Fee for Merger Reviews
- On March 28, 2025, the Bureau announced that the filing fee for merger reviews has increased from C$86,358.76 to C$88,690.45, effective April 1, 2025. The filing fee applies to parties filing a pre-merger notification or requesting an Advance Ruling Certificate.
Investment Canada Act
Foreign Investment Monitor
Non-Cultural Investments
February 2025 Highlights
- 79 notifications filed (56 filed for acquisitions, 23 for the establishment of a new Canadian business)
- Country of ultimate control: United States (52%); France (8%); China (6%); Germany (6%); Spain (5%); Iran (5%); United Kingdom (4%)
January – February 2025 Highlights
- One reviewable investment approval and 184 notifications filed (148 filed for acquisitions, 36 for the establishment of a new Canadian business)
- Country of ultimate control: United States (57%); France (8%); Germany (4%); China (4%); United Kingdom (4%); Iran (3%); Spain (2%)
Investment Canada Act Non-Cultural Investment Filings and Approvals, January – February 2025
Non-Enforcement Activity
New Cabinet Appointments Announced
- On March 14, 2025, Prime Minister Mark Carney introduced the new federal cabinet, including new Ministers responsible for enforcing the Investment Canada Act (Act). The new cabinet includes Anita Anand as Minister of Innovation, Science and Industry, the primary Minister responsible for enforcing the Act, replacing François-Philippe Champagne. Further, Steven Guilbeault has been appointed to the newly created role of Minister of Canadian Culture and Identity, Parks Canada and will be responsible for assessing investments in "cultural businesses" that fall under the Act's jurisdiction. This position replaces the Minister of Canadian Heritage role in cabinet, which was most recently held by Pascale St-Onge.
Blakes Notes
- On April 1, 2025, the Competition, Antitrust & Foreign Investment group was once again recognized as "Regional Firm of the Year – Americas" at the Global Competition Review Awards.
- 14 Blakes Partners were recognized as leaders in Competition Law in the 2025 edition of The Canadian Legal Lexpert Directory.
- Browse our thought-leadership insights from the Competition, Antitrust & Foreign Investment group to learn more.
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