Transfer Pricing and Tax Treaty Case Law in Canada
Transfer Pricing Case Law in Canada
Tax Treaty Case Law in Canada
RBRT is transfer pricing in Canada, transfer pricing documentation in Canada, Canadian transfer pricing documentation, transfer pricing method in Canada, and Canadian transfer pricing: Transfer pricing in Canada, Canadian Income Tax Act, Section 247, IC 87-2R International Transfer Pricing, Arm’s length principle, Contemporaneous Documentation, 247(4), Base Erosion and Profit Shifting (BEPS), Pacific Association of Tax Administrators (PATA) Transfer Pricing Documentation Package, OECD Transfer Pricing Guidelines, OECD Report on the transfer pricing aspects of business restructurings, OECD Revised discussion draft on transfer pricing aspects of intangibles, OECD Special considerations for intangibles, OECD 2010 Report on the Attribution of Profits to Permanent Establishments, OECD Multi-Country Analysis of Existing Transfer Pricing Simplification Measures, European Commission Joint Transfer Pricing Forum, Transfer Pricing, Transfer pricing in Canada, Landmark transfer pricing court cases, Transfer pricing court cases, International tax cases, RBRT Inc., RBRT Transfer Pricing, TPM-01 – Referrals to the Transfer Pricing Review Committee (Archived), TPM-02 – Repatriation of funds by Non-residents – Part XIII, TPM-03 – Downward Transfer Pricing Adjustments under Subsection 247(2), TPM-04 – Third Party Information, TPM-05 – Contemporaneous Documentation (Archived), TPM-05R – Requests for Contemporaneous Documentation, TPM-06 – Bundled Transactions, TPM-07 – Referrals to the Transfer Pricing Review Committee (Archived), TPM-08 – The Dudney Decision: Effects on Fixed Base or Permanent Establishment Audits and Regulation 105 Treaty-Based Waiver Guidelines, TPM-09 – Reasonable efforts under section 247 of the Income Tax Act, TPM-10 – Advance Pricing Arrangement Rollback (Archived), TPM-11 – Advance Pricing Arrangement (APA) Rollback, TPM-12 – Accelerated Competent Authority Procedure (ACAP), TPM-13 – Referrals to the Transfer Pricing Review Committee, TPM-14 – 2010 Update of the OECD Transfer Pricing Guidelines, Base Erosion and Profit Shifting (BEPS), Transfer pricing in Canada, BEPS Project, BEPS action plan, Exchange of information, Hybrid Mismatch Arrangements, OECD Country-by-country reporting, OECD Country-by-country reporting Template, Tax Treaty, Tax haven, T106 Information Return of Non-Arm’s Length Transactions with Non-Residents, Guidelines for Treaty-Based Waivers Involving Regulation 105 Withholding; 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RBRT is all about transfer pricing Base erosion and profit shifting initiative (BEPS), Master file, Local file and Country-by-Country reporting services by RBRT: Assessment of tax risks for transfer pricing purposes, Management of tax risks for transfer pricing purposes, Analysis, recommendations and implementation of transfer pricing policies and procedures, Analysis, recommendations and implementation of transfer pricing documentation, Analysis, recommendations and implementation of value chain management, Relevance of advance pricing arrangements (APA), Consulting on advance pricing arrangements (APA), Documentation for advance pricing arrangements (APA); Transfer pricing documentation services by RBRT: Preparation of transfer pricing documentation, Assembling of transfer pricing documentation, Analysis of transactions, Economic analysis, Comparability analysis optimization, Functional analysis optimization, Functions valuation for transfer pricing purposes, Risks valuation for transfer pricing purposes, Assets valuation for transfer pricing purposes, Transfer pricing method optimization, Optimized search for comparables, Transfer pricing economic study and report; Transfer pricing tax relief, dispute resolution and litigation services by RBRT: Consulting through the CRA and IRS transfer pricing audit stage, Consulting through the CRA and IRS objection and appeal process, Consulting through the Competent Authority process, Economic expert study and report for the CRA and IRS objection and appeal process, Transfer pricing economic study and report for the objection and appeal process, Transfer pricing economic study and report for tax litigation, Transfer pricing economic expert-witness for tax litigation; Transfer pricing policies and risk management services by RBRT: Assessment of tax risk for transfer pricing purposes, Management of tax risk for transfer pricing purposes, Assessment of transfer pricing policies and procedures, Design of transfer pricing policies and procedures, Implementation of transfer pricing policies and procedures, Evaluation of transfer pricing policies and procedures; Advance Pricing Arrangements (APA) services by RBRT: Analysis of transactions, Comparability analysis, Relevance of advance pricing arrangements (APA), Consulting and documentation on advance pricing arrangements (APA): prefiling meeting, request, submission, documentation, site visits, economic study and report, transfer pricing report, Design and assembly of advance pricing arrangements (APA) request, Design and assembly of advance pricing arrangements (APA) submission, Economic expert study and report for advance pricing arrangements (APA) submission; Value chain management for transfer pricing services by RBRT: Function valuations and strategic location, Risk valuations and strategic location, Asset valuations and strategic location, Intangible valuation and strategic location, Intragroup service valuations and strategic location, Financial transaction (guarantee fees, insurance, cost and cash pooling, etc.) valuation and strategic location, Business restructuring. 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RBRT assists with treaty-based requests, returns and waivers such as non-resident Canadian income tax matters, residency or residence matters, permanent establishment matters, transfer pricing adjustments, double taxation of income from real property or business profits, tax withheld (withholding) on dividends, interests, royalties, management fees, services provided by non-residents, income from real property, issues on income from interest or related to capital gains, double taxation arising on income from employment, pension and annuities, Part XIII Tax withholding under the Canadian Income Tax Act, Regulation 102 and regulation 105 withholding waivers, double taxation on other types of income and Foreign tax credit matters.