OECD – Timing Issues

Matthew Wall OECD

Matthew Wall of MDW submitted detailed comments to the OECD on their Discussion Draft for Timing Issues in Transfer Pricing.

OECD – Safe Harbours and MOUs

Matthew Wall OECD

Matthew Wall of MDW submitted detailed comments to the OECD on their Discussion Draft for Chapter IV on Safe Harbours including a sample Memoranda of Understanding (MOUs).

OECD Intangibles

Matthew Wall OECD

Matthew Wall of MDW submitted detailed comments to the OECD on their Discussion Draft for Chapter VI on Intangibles.

International Tax Review

Matthew Wall Tax

International Tax Review published “Transfer pricing adjustments can trigger withholding taxes” by Matthew Wall and Susan Robins.

Transfer Pricing Week

Matthew Wall Transfer Price

Transfer Pricing Week interviewed Matthew Wall for “Canada’s budget could set global revenue trend” on withholding taxes.

Federal Budget

Matthew Wall Tax, Transfer Price

MDW explained Canada changed the transfer pricing rules to include a secondary adjustment for withholding taxes.

Bloomberg BNA

Matthew Wall Bloomberg BNA, Tax

Bloomberg BNA published “A Lesson from Alberta Printed Circuits: Intangibles Key to Proper TNMM Analysis” by Shaun MacIsaac and Matthew Wall who were the legal counsel and expert witness in Alberta Printed Circuits Ltd. v. The Queen.

International Tax Review

Matthew Wall Tax

International Tax Review interviewed Shaun MacIsaac for “Lead defence in Canadian case discusses outcome” where he said “In the reasons for judgment, the court relied heavily on the expert report and testimony by Matthew Wall of MDW Consulting.”

OECD and CRA Update

Matthew Wall CRA Updates, OECD

MDW explained the OECD and CRA linked the two concepts of valuations and transfer pricing for intangibles. If valuation methods are for purchasing intangibles from unrelated parties, and transfer pricing methods are for licensing intangibles to related parties, can valuation …

Transfer Pricing Litigation

Matthew Wall Transfer Price

MDW commented on the Supreme Court of Canada hearing between GlaxoSmithKline Inc. v. The Queen regarding the arm’s length price for the active ingredient of a blockbuster drug and whether, or not, it should include the related intangibles.