Transfer Pricing in Canada: The Transfer Pricing Penalties 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). They are complemented...
En savoir plusTransfer Pricing in Canada: Reasonable efforts to Determine an Arm’s Length Price 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...
En savoir plusTransfer Pricing in Canada: Contemporaneous Documentation 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). The Canadian transfer pricing rules...
En savoir plusTransfer 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)....
En savoir plusTransfer Pricing in Canada: An Overview 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). They are complemented by...
En savoir plusFinance Canada has released its Notice of Ways and Means Motion to introduce an Act to implement a multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting It is available here: https://www.fin.gc.ca/drleg-apl/2018/adtpfe-edipef-eng.asp. As it is...
En savoir plusThis blogpost was originally released in French on poesiefiscale.ca Le printemps s’en vient : les camps d’entraînement vont actuellement bon train au baseball. Le budget fédéral 2018, déposé le 27 février 2018, contient lui aussi son lot de balles courbes...
En savoir plusRead our latest piece published in Intertax 45/12 titled “Contractual Arrangements and the Delineation of a Transaction: A Duo in Crisis Mode”. Summary - "This article highlights the evolving relationship between contractual arrangements and the delineation of a transaction for transfer...
En savoir plusProfit 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...
En savoir plusThis article reviews in detail the transfer pricing documentation rules in Canada. We analyse how Canada implemented the OECD’s transfer pricing documentation recommendations, that provide for a country-by-country report, a master file, and a local file, to combat base erosion...
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