CRA Update

Matthew Wall Transfer Price

Big changes for international tax and transfer pricing in Canada’s Federal Budget 2021.

University of Waterloo

Matthew Wall Transfer Price

The University of Waterloo invited Matthew Wall as a guest speaker on transfer pricing for the Young Tax Professionals.

OECD – Digital Taxes

Matthew Wall OECD, Transfer Price

MDW’s bulletin summarizes the OECD’s Blueprint on digital taxes for 2021 or 2022 once a consensus is reached among participating nations.

CRA Update

Matthew Wall CRA Updates, Transfer Price

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 It has been archived and will not be updated.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.

OECD – Financial Transactions

Matthew Wall OECD

The OECD issued a new chapter for pricing financial transactions – e.g., loans, cash pooling, hedging, guarantees, captive insurance, and rates of return.

OECD – Cost Plus Models

Matthew Wall OECD

MDW bulletin explains the new concerns and additional steps needed for multinational companies that use cost plus models in their corporate tax structure.

CRA Update

Matthew Wall CRA Updates, Transfer Price

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.

Expert Witness

Matthew Wall Expert Witness

Legal counsel relied on Matthew Wall’s expert report on transfer pricing to settle an appeal in the Tax Court of Canada.