BlackBerry appeals $17 million reassessment for R&D services provided by US affiliates.
Canada – Digital Taxes
MDW news on Canada under pressure for its digital sale tax and why this is a complex issue.
Canada – Digital Taxes
MDW news on Canada willing to use a digital sales tax if the OECD two pillar approach fails.
Transfer Pricing Litigation
MDW news on taxpayer settles with the CRA on the interest rate for a related party loan.
Policy Update
MDW summarizes the key changes proposed by the UK in its transfer pricing law and administrative guidance.
Policy Update
MDW summarizes the key changes proposed by Canada in its transfer pricing law and administrative guidance.
CRA Update
Canada’s Budget 2023 includes an update on Pillar One, Pillar Two, revisions to GAAR, and a public consultation on transfer pricing.
CRA Update
MDW explains the CRA guidance on transfer pricing for e-commerce transactions.
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.