Singapore provides detailed guidance on related party loans and interest.
CRA Update
The CRA issued a new Transfer Pricing Memo TPM-02R for Part XIII withholding tax, interest and penalties on transfer pricing adjustments.
Canada’s Public Consultation
Finance Canada seeking public input on Mandatory Disclosure Rules and Digital Sales Tax.
CRA Update
Canada’s parliament studying the CRA’s efforts to combat tax avoidance and evasion.
CRA Update
Big changes for international tax and transfer pricing in Canada’s Federal Budget 2021.
University of Waterloo
The University of Waterloo invited Matthew Wall as a guest speaker on transfer pricing for the Young Tax Professionals.
Transfer Pricing Litigation
The Supreme Court of Canada dismissed the transfer pricing appeal on recharacterization in the Queen vs Cameco Corporation.
OECD – Digital Taxes
MDW’s bulletin summarizes the OECD’s Blueprint on digital taxes for 2021 or 2022 once a consensus is reached among participating nations.
Canada – Digital Taxes
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.
CRA Update
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 It has been archived and will not be updated.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.