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

By Robert Robillard - 15 janvier 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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RBRT Comments on Transactional Profit Splits in the BEPS Context

By Robert Robillard - 13 octobre 2017

The OECD recently released the comments received on its latest discussion draft on transactional profit splits in the context of the Base Erosion and Profit Shifting initiative (BEPS). These comments along with the comments received on the latest discussion draft on...

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