OECD – Digital Taxes

Matthew Wall OECD, Transfer Price

MDW’s bulletin summarizes the OECD’s Blueprint on digital taxes for 2021 or 2022 once a consensus is reached among participating nations.

CRA Update

Matthew Wall CRA Updates, Transfer Price

The CRA has cancelled the IC 87-2R on International Transfer Pricing. It has been archived and will not be updated. Further, TPM-03 on Downward Adjustments is under revision.

CRA Update

Matthew Wall CRA Updates, Transfer Price

Finance Canada proposed changes to the Income Tax Act including changes for transfer pricing adjustments that involve GAAR. Two examples deal with related party loans and interest.

Transfer Pricing Litigation

Matthew Wall Transfer Price

A transfer pricing settlement was reached in Silver Wheaton Corp. v The Queen for 2005 to 2010 and later. The CRA accepts that income earned by the foreign subsidiary is not subject to tax in Canada, and the taxpayer accepts …

CRA Update

Matthew Wall CRA Updates, Transfer Price

The CRA updated its website for transfer pricing, making it easier to navigate with helpful links to the income tax act and other reference materials for complying with the transfer pricing rules in Canada.

CRA Update

Matthew Wall CRA Updates, Transfer Price

The 2018 Federal Budget included International Tax Measures to enhance the CRA’s (i) access to information, (ii) audit, and (iii) reassessment of transactions between a Canadian taxpayer and its foreign affiliates.

CRA Update

Matthew Wall CRA Updates, Transfer Price

The CRA will receive $1 billion to crack down on tax evasion and avoidance. The 2018 Federal Budget committed $90.6 million over five years, plus $524 million in the 2017 Budget and $444 million in the 2016 Budget.

IRS Update

Matthew Wall Tax, Transfer Price

The U.S. corporate tax rate is now 21% (down from 35%) along with other important changes. Companies should meet with their tax and transfer pricing advisors for specific advice on their U.S. operations.