OECD – Financial Transactions

Matthew Wall OECD

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

OECD – Profit Splits

Matthew Wall OECD

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.

OECD – Intangibles

Matthew Wall OECD

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.

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.

OECD – BEPS

Matthew Wall OECD, Transfer Price

Matthew Wall of MDW submitted comments to the OECD on the Discussion Draft for BEPS Action 8 implementation guidance on Hard-to-Value Intangibles.

CRA Update

Matthew Wall CRA Updates, Transfer Price

MDW provided an update on the Canada Revenue Agency’s fight against tax avoidance and evasion regarding the Panama Papers.