CRA Update

Matthew Wall CRA Updates, Transfer Price

Canada’s Budget 2023 includes an update on Pillar One, Pillar Two, revisions to GAAR, and a public consultation on transfer pricing.

CRA Update

Matthew Wall Transfer Price

MDW explains how Canada’s changes on economic substance can strengthen the General Anti-Avoidance Rules (GAAR).

Expert Witness

Matthew Wall Transfer Price

Matthew Wall submitted an expert report to legal counsel on transfer pricing for an appeal in the Tax Court of Canada.    

CRA Update

Matthew Wall CRA Updates, Transfer Price

The CRA issued a new Transfer Pricing Memo TPM-02R for Part XIII withholding tax, interest and penalties on transfer pricing adjustments.