MDW summarizes the key changes proposed by the UK in its transfer pricing law and administrative guidance.
Policy Update
MDW summarizes the key changes proposed by Canada in its transfer pricing law and administrative guidance.
CRA Update
Canada’s Budget 2023 includes an update on Pillar One, Pillar Two, revisions to GAAR, and a public consultation on transfer pricing.
CRA Update
MDW explains the CRA guidance on transfer pricing for e-commerce transactions.
CRA Update
MDW explains how Canada’s changes on economic substance can strengthen the General Anti-Avoidance Rules (GAAR).
Transfer Pricing Litigation
MDW explains why transfer pricing disputes are difficult to resolve for business restructuring, intangibles and profits.
Expert Witness
Matthew Wall submitted an expert report to legal counsel on transfer pricing for an appeal in the Tax Court of Canada.
OECD – Digital Taxes
Canada’s Budget 2022 announced it will adopt the OECD’s digital tax model once it is ready.
Transfer Pricing Litigation
Burlington Resources withdraws its appeal over the reassessment of guarantee fees.
Financial Transactions
Switzerland updates its safe harbour rules for related party loans and interest.