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.
Switzerland updates its safe harbour rules for related party loans and interest.
Singapore provides detailed guidance on related party loans and interest.
The CRA issued a new Transfer Pricing Memo TPM-02R for Part XIII withholding tax, interest and penalties on transfer pricing adjustments.
Finance Canada seeking public input on Mandatory Disclosure Rules and Digital Sales Tax.
Canada’s parliament studying the CRA’s efforts to combat tax avoidance and evasion.