Kaitlin Gray Kaitlin Gray

Transfer pricing in times of tariff turmoil

We examine the intricate relationship between tariffs and transfer pricing, with insight on how protectionist measures impact pricing.

Canadian global minimum tax, digital services tax and other international tax reforms

The international tax landscape has seen substantial and complex changes in recent years, with still more underway.

Dow Chemical and Iris Technologies: Supreme Court rules on jurisdictional issues in tax matters

In this Update: On June 28, 2024, the Supreme Court released its decisions in Dow Chemical and Iris Technologies regarding the respective...

Canadian government moves ahead with Global Minimum Tax Act

Canada’s Pillar Two legislation, the Global Minimum Tax Act, is introduced in Parliament. In their Update, Patrick Marley, Oleg Chayka, Ilana...

Transfer Pricing 2024: Law and Practice

The federal government has plans to update the rules that govern transfer pricing — the pricing one branch or division or group of a company...

CRA releases revised APA guidance

The CRA revised its guidance on Advance Pricing Arrangements, introducing significant updates to criteria for acceptance into the program. The...

Transfer pricing proposals infuse Canada’s tax laws with OECD concepts

Canada’s transfer pricing rules ensure that, for Canadian income tax purposes, the pricing of non-arm’s length cross-border transactions adheres...

Draft Canadian Pillar Two global minimum tax legislation and revised DST legislation

The Department of Finance released draft legislation implementing two key measures of the OECD’s Pillar Two global minimum tax in Canada: the...