Transfer Pricing in Canada: Reporting of Non-Arm’s Length Transactions with Non-Residents

By Robert Robillard - 15 January 2019

Transfer Pricing in Canada: Reporting of Non-Arm's Length Transactions with Non-Residents This blog post is also available in pdf format here. Legislation Since 1997, Canada’s transfer pricing rules have been included in section 247 of the Canadian Income Tax Act (ITA)....

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“Profits” in Profit Split Methods: Hazardous Crossovers on the way to Global Formulary Apportionment

By Robert Robillard - 16 November 2017

Profit split methods have had global formulary apportionment inclines lately. This second piece on profit split methods was recently published in Tax Analysts: ““Profits” in Profit Split Methods: Hazardous Crossovers on the way to Global Formulary Apportionment”, Tax Notes International, October...

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