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
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
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
Legal counsel relied on Matthew Wall’s expert report on transfer pricing to settle an appeal in the Tax Court of Canada.
Transfer Pricing Litigation
A transfer pricing settlement was reached in Silver Wheaton Corp. v The Queen for 2005 to 2010 and later. The CRA accepts that income earned by the foreign subsidiary is not subject to tax in Canada, and the taxpayer accepts …
OECD – Financial Transactions
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
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
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
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
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.