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From transfer pricing to tax treaties: Canadian cross-border tax update

Author(s): Monica Biringer, Patrick Marley, Amanda Heale

Dec 18, 2018

The two most significant Canadian cross-border tax developments in 2018 relate to transfer pricing and tax treaties. On transfer pricing, Osler successfully represented the taxpayer, Cameco Corporation, at the Tax Court of Canada in the first case to address Canada’s transfer pricing “recharacterization” rule. On tax treaties, Canada introduced legislation in 2018 (Bill C-82) to enact the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting — also known as the Multilateral Instrument or MLI — into Canadian law. This is the next step in the process for Canada to ratify the MLI – which will make significant amendments to many of Canada’s tax treaties.

Taxpayer prevails in landmark transfer-pricing dispute

On September 26, the Tax Court of Canada released its decision in Cameco Corporation v Her Majesty the Queen, 2018 TCC 195...


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