The Supreme Court of Canada dismissed the transfer pricing appeal on recharacterization in the Queen vs Cameco Corporation.
MDW’s bulletin summarizes the OECD’s Blueprint on digital taxes for 2021 or 2022 once a consensus is reached among participating nations.
MDW’s bulletins track Canada’s plan for digital taxes from an election promise in 2019 to a throne speech, Auditor General report, and mini-budget in 2020.
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 It has been archived and will not be updated.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.
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.
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 …
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.
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.
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.
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.