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.
Matthew Wall of MDW submitted comments to the OECD’s latest revision of 2017 Discussion Draft for the guidance on profit splits.
Matthew Wall of MDW submitted comments to the OECD on the Discussion Draft for BEPS Action 8 implementation guidance on Hard-to-Value Intangibles.
MDW provided an update on the Canada Revenue Agency’s fight against tax avoidance and evasion regarding the Panama Papers.