Transfer Pricing Transfer Pricing

Finance proposes tying transfer-pricing rules to OECD guidelines

An article by Kaitlin Gray discusses Finance’s consultation paper proposing to rewrite Canada’s transfer pricing rules.

TPM-02R: Transfer-Pricing Secondary Adjustments and Repatriation

TPM-02R replaces Transfer Pricing Memorandum TPM-02, “Repatriation of Funds by Non-Residents—Part XIII Assessments,” and certain paragraphs...

Continued uncertainty following recent CRA position on Tax Treaty anti-avoidance rule

The most significant treaty modification implemented through the MLI was the addition of a broad anti-avoidance rule known as the principal purpose...

Supreme Court denies Crown’s request for leave to appeal Cameco transfer pricing decision

On February 18, 2021, the Supreme Court of Canada declined the Crown’s application seeking leave to appeal the June 2020 decision of the Federal...

Osler submission on the OECD Pillar One and Pillar Two Blueprints

Earlier in 2020, the OECD published blueprint reports on Pillar One and Pillar Two and launched a public consultation process on its two-pillar...

From treaty shopping to FAPI and transfer pricing: Notable international tax cases

Three decisions of the Federal Court of Appeal (FCA) released during the COVID-19 pandemic have caused renewed interest in certain fundamental...

COVID-19 tax measures and proposed international tax reform

Two significant tax developments in 2020 were Canada’s measures in response to COVID-19 and Canada’s participation with the OECD’s pursuit of...

OECD provides additional detail on Pillar One proposal in update on international tax reform – Seeking consensus-based solution in 2020

On January 31, 2020, the OECD/G20 Inclusive Framework on BEPS released the Statement by the OECD/G20 Inclusive Framework on BEPS on the Two-Pillar...