MDW explains the CRA guidance on transfer pricing for e-commerce transactions.
MDW explains how Canada’s changes on economic substance can strengthen the General Anti-Avoidance Rules (GAAR).
MDW explains why transfer pricing disputes are difficult to resolve for business restructuring, intangibles and profits.
Matthew Wall submitted an expert report to legal counsel on transfer pricing for an appeal in the Tax Court of Canada.
Canada’s Budget 2022 announced it will adopt the OECD’s digital tax model once it is ready.
Burlington Resources withdraws its appeal over the reassessment of guarantee fees.