MDW explains the CRA guidance on transfer pricing for e-commerce transactions.
CRA Update
MDW explains how Canada’s changes on economic substance can strengthen the General Anti-Avoidance Rules (GAAR).
Transfer Pricing Litigation
MDW explains why transfer pricing disputes are difficult to resolve for business restructuring, intangibles and profits.
Expert Witness
Matthew Wall submitted an expert report to legal counsel on transfer pricing for an appeal in the Tax Court of Canada.
OECD – Digital Taxes
Canada’s Budget 2022 announced it will adopt the OECD’s digital tax model once it is ready.
Transfer Pricing Litigation
Burlington Resources withdraws its appeal over the reassessment of guarantee fees.
Financial Transactions
Switzerland updates its safe harbour rules for related party loans and interest.
Financial Transactions
Singapore provides detailed guidance on related party loans and interest.
CRA Update
The CRA issued a new Transfer Pricing Memo TPM-02R for Part XIII withholding tax, interest and penalties on transfer pricing adjustments.
Canada’s Public Consultation
Finance Canada seeking public input on Mandatory Disclosure Rules and Digital Sales Tax.