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Searching Content indexed under Transfer Pricing by Bennett Jones LLP ordered by Published Date Descending.
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1
CBSA Publishes Update of Trade Verification Priorities: Are You Ready?
The Canada Border Services Agency (CBSA) updated its online statement of its current trade verification (audit) priorities in July 2019. Importers of goods targeted for verification would be wise
Canada
6 Sep 2019
2
Business Measures In 2019 Federal Budget
The 2019 Canadian federal budget was released on March 19, 2019.
Canada
29 Mar 2019
3
VDP Overhaul Coming Sooner Than You Thought
Earlier this month, we reported that a senior representative of the CRA had announced that it was "highly likely" that the incoming changes to the Voluntary Disclosures Program (VDP) ...
Canada
22 Dec 2017
4
Is Your Customs Compliance BEPS Ready?
2016 was the first year of the new transfer pricing reporting regime called Country-by-Country Reporting (CbCR).
Canada
21 Feb 2017
5
Tax Uncertainty Hinders Global Growth: Business Survey Launched
Businesses are invited to participate in an international survey from the OECD to measure the impact of tax uncertainty on their investment decisions.
Canada
8 Nov 2016
6
WCO Technical Committee On Customs Valuation Sanctions Use Of Transfer Pricing Studies
Generally, transfer pricing studies rely on OECD tax principles; economists apply these principles with a focus on income tax outcomes.
Canada
16 May 2016
7
Transfer Pricing Customs Duty Refund Applications – Let’s Do It Right
The Canada Border Services Agency (CBSA) has informed the Canadian importing community that importers may be entitled to obtain customs duty refunds in connection with downward transfer pricing adjustments.
Canada
18 Mar 2015
8
CRA Releases Important Transfer Pricing Guidance On Management Fees And Other Intra-Group Services
The document expands considerably upon brief guidance on this topic in CRA's main Information Circular on Transfer Pricing, which dates back to 1999.
Canada
2 Mar 2015
9
Canadian Customs Authority Shifts Gears On Import Duty Refunds
The CBSA has made a long-sought-for change in its policy to allow duty refunds in the event of qualifying downward transfer price adjustments by importers.
Canada
29 Jan 2015
10
Canadian Importers May Now Seek Import Duty Refunds
Since the introduction of the Transaction Value System of customs valuation by Canada on January 1, 1985, the Canada Border Services Agency (CBSA) has maintained a stated policy of denying refund claims of related party importers who seek to amend declared values for duty to account for adjustments that decrease transfer prices after importation.
Canada
20 Jan 2015
11
BEPS Tail Shouldn’t Wag Global Investment Dog
I spoke recently on a panel in Tokyo on the future of international tax planning after BEPS (the OECD’s & G20’s Action Plan to counter Base Erosion & Profit Shifting).
Worldwide
26 Nov 2014
12
Judicial Review Application Preserved In Transfer Pricing Penalty Case
A recent Federal Court of Appeal (FCA) case illustrates how contentious transfer pricing disputes can be – even one a taxpayer believed had been resolved!
Canada
11 Oct 2014
13
Revised CRA Policy Heralds Focus On Contemporaneous Transfer Pricing Documentation
CRA released an updated transfer pricing memorandum in March, which describes the procedural aspects of transfer pricing documentation requirements.
Canada
14 Jul 2014
14
Businesses Face More Onerous Transfer Pricing Documentation And Country-By-Country Tax Reporting
The OECD proposes to reform transfer pricing documentation for multinational enterprises and to impose onerous country-by-country reporting obligations.
Canada
10 Mar 2014
15
Taxpayer Loses Canadian Transfer Pricing Case
A recent transfer pricing case from the Tax Court of Canada (McKesson Canada Corporation v The Queen) establishes a broad interpretation of the "regular" (non-recharacterization) transfer pricing rule in the Income Tax Act and offers guidance on the adequacy of contemporaneous documentation. It is therefore an important case for multinationals doing business in Canada.
Canada
27 Jan 2014
16
Supreme Court Endorses Key Tax Principle: Tax Law Should Follow Private Law Agreements
The Supreme Court of Canada recently endorsed a fundamental principle in Canadian tax law – namely that absent sham or statutory recharacterization rules, "tax law applies to transactions governed by, and the nature and legal consequences of which are determined by reference to, the common law or the civil law" (Québec (Agence du Revenu) v Services Environnementaux AES inc., 2013 SCC 65 at para 45).
Canada
18 Dec 2013
17
OECD Launches Action Plan On Base Erosion And Profit Shifting
The OECD has recently released its Action Plan on Base Erosion and Profit Shifting.
Canada
25 Jul 2013
18
OECD Revising Intangibles Transfer Pricing Discussion Draft
At the OECD International Tax Conference in DC on June 3 and 4, Joe Andrus, Head of the OECD’s Transfer Pricing Unit, announced that the OECD’s Discussion Draft on Intangibles released in 2012 is under revision in two key areas: definition of intangibles and ownership and entitlement to intangibles related returns.
Canada
17 Jun 2013
19
International Tax & Transfer Pricing Strategies In The Crosshairs
The OECD recently issued a report targeting corporate tax planning and transfer pricing strategies, which it asserts constitute a serious risk to tax revenues, tax sovereignty among nations and tax fairness.
Canada
28 Feb 2013
20
Supreme Court Of Canada Establishes Important Principles In Transfer Pricing
The Supreme Court of Canada recently released its judgment in The Queen v Glaxo Smith Kline Inc., (Glaxo), which is the Court’s first pronouncement on Canada’s transfer pricing rules.
Canada
10 Dec 2012
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