Amanda Heale Amanda Heale

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.

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...

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...

OECD releases transfer pricing guidance on a simplified and streamlined approach (Amount B of Pillar One)

The OECD has released its first transfer pricing report on Amount B of Pillar One, which introduces a simplified transfer pricing methodology for...

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...

Canadian Tax Law Insights: Managing tax audits to prevent and resolve disputes with the CRA – Part 2

Members of Osler’s Tax Group provide guidance and best practices for preventing and resolving tax disputes earlier, and more effectively, in light...

2023 Budget Briefing: Key Updates and Proposals

Watch members of Osler’s Tax practice group for an informative webinar discussion of recent legislative amendments and proposals included in the...

Tax avoidance in Canada and the future of the GAAR

The Canadian Income Tax Act (Tax Act) contains a general anti-avoidance rule (GAAR) which can negate tax benefits arising from “abusive” tax...