Big changes for international tax and transfer pricing in Canada’s Federal Budget 2021.
The University of Waterloo invited Matthew Wall as a guest speaker on transfer pricing for the Young Tax Professionals.
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 It has been archived and will not be updated.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.
The OECD issued a new chapter for pricing financial transactions – e.g., loans, cash pooling, hedging, guarantees, captive insurance, and rates of return.
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.
Legal counsel relied on Matthew Wall’s expert report on transfer pricing to settle an appeal in the Tax Court of Canada.