MDW bulletin explains the new concerns and additional steps needed for multinational companies that use cost plus models in their corporate tax structure.
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 OECD released a discussion draft on financial transactions – e.g., loans, cash pooling, hedging, guarantees, captive insurance. Public comments are due by 7 Sept 2018
The OECD released new guidance on profit split methods including 16 examples to show how the guidance can be followed for using a method that historically was not used very often.
The OECD released new guidance on hard-to-value intangibles governing when – years later – tax authorities can use actual results to test the assumptions used by taxpayers in the valuation of intangibles.
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.