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Searching Content indexed under Transfer Pricing by Gowling WLG ordered by Published Date Descending.
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1
Transfer Pricing: What's New In Canada (Part II)
In Part I of this article,[1] we provided an overview of transfer pricing developments in Canada since the start of the Organization for Economic Cooperation and Development's
Canada
4 Sep 2019
2
Transfer Pricing: What's New In Canada (Part I)
Since 2012, there have been unprecedented developments in Canada and globally in the area of international tax. The sheer volume and complexity
Canada
5 Aug 2019
3
Be Careful What You Ask For: Limits On Oral Interviews Confirmed In Cameco
MNR v Cameco Corporation, 2019 FCA 67 ("Cameco") was an unsuccessful appeal by the Crown of a failed compliance order application in the Federal Court ("FC").
Canada
23 May 2019
4
Budget 2019 : Positionnement en vue des élections d'automne
Les taux marginaux d'imposition les plus élevés du Canada étant décrits par certains analystes comme étant « punitivement élevés » et l'économie canadienne glissant vers un taux de croissance annualisé de seulement ...
Canada
21 Mar 2019
5
Budget 2019: Positioning For A Fall Election
With Canada's top marginal tax rates described by some analysts as "punitively high," and with the Canadian economy sliding to an annualized rate of growth of only 0.4 per cent in the fourth quarter, many were hoping for tax reductions in Budget 2019 that would help make Canada more competitive.
Canada
21 Mar 2019
6
Disruptions Provide Opportunities In The Automotive Industry: How Transfer Pricing Can Help
Record vehicle sales around the world have been motivated, in large part, by expanding global trade agreements that make the buying and selling of automobiles relatively easy.
Canada
29 Oct 2018
7
Anticipating The Tax Implications Of Brexit
While it is still too early to take a position on the actual consequences of the Brexit, the main tax implications for groups with operations both in France and in the UK can and should already be anticipated.
European Union
10 Sep 2018
8
Bloomberg Tax Transfer Pricing Forum
If a senior manager or management team is relocated into or out of your jurisdiction, does your country have a view about whether the transfer is purely a services transfer, or includes an intangible asset such as goodwill ...
France
17 Jan 2018
9
Minister's Audit Request Failed To Meet Proportionality Principle
Sanity prevailed in a recent Federal Court ("FC") decision involving an application by the Minister of National Revenue ("Minister") to compel a taxpayer to produce approximately 25 employees...
Canada
26 Sep 2017
10
The Sifto Decision — Is The Minister Bound By MAP Settlements?
On March 10, 2017, the Tax Court of Canada ("TCC") delivered its decision in Sifto Canada Corp. v. The Queen1 regarding the legal effect of a transfer pricing settlement reached under the Mutual Agreement...
Canada
22 May 2017
11
Transfer Pricing Agreements - France Chapter
To what extent are a multinational enterprise's intra-group contracts respected for transfer pricing purposes?
Canada
13 Apr 2017
12
Tax Wars: It's Time To Think Strategically On International Tax Issues
International tax issues and in particular transfer pricing, is often cited as the number one concern of businesses operating beyond their home border.
Canada
16 Mar 2017
13
The Transfer Pricing Controversy "Landscape" - France Chapter
There are various sources of transfer pricing controversy in France. While it is clearly hard if not impossible to quantify the usual elements of debate between the French Tax Authorities...
France
1 Mar 2017
14
Changes Coming To Country-By-Country Transfer Pricing Documentation Requirements
Businesses with international operations need to be aware of changes to the required transfer pricing documentation that will apply in the near future.
Canada
30 Aug 2016
15
Québec Now Taxes Off-Title Transfers Of Real Property
The Québec Budget tabled on March 17, 2016, (the "Budget") announces significant changes to the regime governing the duties on the transfer of real property (immovables) in Québec.
Canada
17 Aug 2016
16
IP Migration Strategies: Pre And Post-BEPS
The largest initiative the transfer pricing world has seen, since the introduction of the OECD's current Transfer Pricing Guidelines, is in its final stages and will result in material changes in the way the global operations of corporate organizations are structured and international transactions are reported...
Canada
20 Jun 2016
17
The "Marzen" Decision: A typical Example Of BEPS
On June 10, 2014, the Tax Court of Canada delivered its most recent decision on transfer pricing, one which involved a Barbados structure.
Canada
14 Oct 2014
18
Resolving Transfer Pricing Disputes In Canada
The growth in international business has led to more Canadian companies transacting across borders with related parties, making transfer pricing an important focus of the CRA.
Canada
14 Oct 2014
19
BEPS, Treaty Shopping And The Canadian Response
The combined efforts of the G20 and the OECD on base erosion and profits shifting or "BEPS" has attracted considerable attention.
Canada
21 Jul 2014
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