Canada: Transfer Pricing

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

Transfer Pricing Disputes: How Forum Choice Alters Outcomes

When the SCC confirmed that discretionary denials under s. 247(10) fall outside the Tax Court's jurisdiction, MEGLobal's appeal was effectively doomed.

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Counter Tax Litigators

Bank Of Nova Scotia v The King – How A Procedural Rule On Loss Carrybacks Triggered $7.9M In Interest Arrears On Tax Not Owing

In Bank of Nova Scotia v His Majesty the King, the FCA confirmed the Tax Court's decision that arrears interest could accrue until the date of a reassessment, even in situations where a subsequent loss carryback effectively offsets most of the reassessed tax liability.

RS

Rotfleisch & Samulovitch P.C.

MEGlobal Canada ULC v. The King: When Split Jurisdiction Leaves A Gap In Relief

On March 26, 2025, the Tax Court of Canada (the "Tax Court") held that it lacked jurisdiction to hear an appeal from MEGlobal Canada ULC (the "Taxpayer").

MT

McCarthy Tétrault LLP

Navigating Cross-Border Tax Challenges

In this exclusive interview with CanadianSME Small Business Magazine, we connect with Errol Tenenbaum, Partner at Robins Appleby LLP, specializing in Tax, Estate Planning, and Business Law, alongside Jordana Lyons...

RA

Robins Appleby LLP

Unlocking Canada's Potential Through Tax Reform: A Letter To Minister Champagne

OH

Osler, Hoskin & Harcourt LLP

Tracer la voie stratégique à suivre dans le cadre d'un différend en matière de prix de transfert

MT

McCarthy Tétrault LLP

Charting The Strategic Path Through A Transfer Pricing Dispute

MT

McCarthy Tétrault LLP

Corporate Tax 2025

BB

BCF Business Law

Transfer Pricing In Times Of Tariff Turmoil

OH

Osler, Hoskin & Harcourt LLP

The Price Is Right? The Role Of Transfer Pricing Across Supply Chains Of Multinational Companies

Canada International

BL

Borden Ladner Gervais LLP

Tax Avoidance Comparative Guide

MT

Miller Thomson LLP

The Tax Court Or The Federal Court? The Supreme Court Of Canada Weighs In On Jurisdictional Issues In Tax Law

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Devry Smith Frank LLP

Federal Court Of Appeal Rules That Arrears Interest Exceed Tax Payable Following Audit And Loss Carryback Request

MT

McCarthy Tétrault LLP

Canadian Global Minimum Tax, Digital Services Tax And Other International Tax Reforms

OH

Osler, Hoskin & Harcourt LLP

Out The Door, Not Off The Hook: Remedies For Employers When Post-Employment Confidentiality Obligations Are Breached

Canada Employment

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Williams HR Law

The Havoc Of The "Standard" Release In Employment Law And Human Rights

Canada Employment

BR

Bow River Law

Court Of Appeal Summaries (August 25 – August 29)

Canada Litigation

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Blaney McMurtry LLP

Webinar: 2025 Global In-House Counsel Survey Report: Unique Insights Into The Global In-House Counsel Profession

Worldwide Law Practice

IC

In-House Counsel Worldwide

The Modernization Of Estate Planning With "Trusty"

Canada Technology

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Goodmans LLP

CRA's Power To Audit And Assess: New Developments, Old Problems

The Canada Revenue Agency (CRA) is afforded considerable latitude in administering and enforcing the Income Tax Act (Act). This latitude is reflected in its power to determine the scope of tax audits...

OH

Osler, Hoskin & Harcourt LLP

Providing Crossborder Inter-Company Goods Or Services? Don't Forget About Transfer Pricing!

In the transportation and logistics industry, as with other industries, it is common for corporations in the same multinational group to provide goods and services to one another. If the parties to such a transaction...

MT

Miller Thomson LLP

SCC Clarifies Jurisdictional Issue In Canadian Tax Disputes: Iris Technologies And Dow Chemicals

On June 28, 2024, the Supreme Court of Canada (SCC) released Dow Chemical Canada ULC (2024 SCC 23) (Dow) and Iris Technologies Inc. (2024 SCC 24) (Iris), two decisions which sought to clarify whether...

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Cassels

No "One-Stop Shopping" To Resolve Tax Disputes: SCC Decisions In Dow Chemical And Iris Technologies

Contrary to what taxpayers often assume, the Tax Court of Canada ("TCC") does not have jurisdiction over a wide range of disputes with Canada Revenue Agency...

ML

McMillan LLP

Jurisdictional Lines Drawn By The SCC: Discretionary Decisions Only Reviewable In Federal Court

BL

Borden Ladner Gervais LLP

Corporate Tax Strategies In Canada

RA

Rosen & Associates

The Quebec Court Of Appeal Rules That A Cross-Border Repo Is Not A Sham And Not Subject To The GAAR

MT

McCarthy Tétrault LLP

La Cour d'appel du Québec juge qu'une opération transfrontalière d'acquisition et de disposition d'actions n'est pas un trompe-l'œil et n'est pas assujettie à la RGAÉ

MT

McCarthy Tétrault LLP

What Does Tax Court Decide? What Does Federal Court Decide? Supreme Court Clarifies Jurisdictions Through Recent Cases: Dow Chemical And Iris Technologies

RS

Rotfleisch & Samulovitch P.C.

The Supreme Court Of Canada Clarifies The Jurisdiction Between The Tax Court Of Canada And The Federal Court

MT

McCarthy Tétrault LLP

Dow Chemical And Iris Technologies: Supreme Court Rules On Jurisdictional Issues In Tax Matters

OH

Osler, Hoskin & Harcourt LLP

Canada's Proposed Patent Box Regime: A Transfer Pricing Perspective

GW

Gowling WLG

Transfer Pricing 2024

OH

Osler, Hoskin & Harcourt LLP

Corporate Tax 2024

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BCF Business Law

Dow Chemical And Iris Technologies: Supreme Court Rules On Jurisdictional Issues In Tax Matters

On June 28, 2024, the Supreme Court released its decisions in Dow Chemical and Iris Technologies regarding the respective jurisdictions of the Tax Court and Federal Court in tax matters

OH

Osler, Hoskin & Harcourt LLP

Canada's Proposed Patent Box Regime: A Transfer Pricing Perspective

In January 2024, the Department of Finance released a consultation paper on a proposed patent box regime, aiming to tax income from certain intellectual properties (IP) at preferential rates lower than the current federal rate.

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Gowling WLG

Transfer Pricing 2024

The primary source of Canada's transfer pricing rules is Section 247 of the Income Tax Act (ITA). Under Subsection 247(2) of the ITA, transactions...

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Osler, Hoskin & Harcourt LLP

Corporate Tax 2024

There are several options available when doing business in Canada. The choice of structure is generally dictated by a number of factors, based mainly on tax and liability considerations.

BB

BCF Business Law

Commentaire relatif au budget fédéral de 2024 – Mesures fiscales

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McCarthy Tétrault LLP

Guide To The Canadian Tax Treatment Of Halal Mortgages: Halal Mortgages Are Shari'ah-Compliant But Taxable In Canada

Islamic or 'halal' financial products are growing globally and this is being driven by the peculiarity of these products in closing financial exclusion gaps affecting Muslims around the globe.

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Rotfleisch & Samulovitch P.C.

CRA Releases Revised APA Guidance

On February 21, 2024, the Canada Revenue Agency (CRA) published a revised Information Circular (Circular) on the Advance Pricing Arrangement (APA) program.

OH

Osler, Hoskin & Harcourt LLP

OECD Releases Transfer Pricing Guidance On A Simplified And Streamlined Approach (Amount B Of Pillar One)

On February 19, 2024, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) released a report on Amount B (Amount B Report) that provides guidance on the simplified...

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Osler, Hoskin & Harcourt LLP

Tax Perspectives: Review Of 2023 & 2024 Outlook

Throughout 2023, the Government of Canada continued its agenda of major tax reform with new legislative proposals and technical amendments to Canadian tax law affecting the general anti-avoidance rule (GAAR), clean economy tax credits, mandatory disclosure rules, and many more.

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McCarthy Tétrault LLP

Avoiding Canadian Tax When Licensing Software Into Canada

SB

Sorbara Law

Key Tax Measures In The 2023 Fall Economic Statement

BC

Blake, Cassels & Graydon LLP

Navigating Cross-Border Tax Controversy

AB

Aird & Berlis LLP

Finance Proposes Tying Transfer-Pricing Rules To OECD Guidelines

OH

Osler, Hoskin & Harcourt LLP

Osler Submission On Transfer Pricing Consultation Paper

OH

Osler, Hoskin & Harcourt LLP

Canada Rejects OECD's One-Year Extension Of Digital Services Tax Moratorium

OH

Osler, Hoskin & Harcourt LLP

Finance Canada Proposes Largest Overhaul Of Canadian Transfer Pricing Legislative Framework

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Gowling WLG

Department Of Finance Releases Consultation Paper Proposing Amendments To Canada's Transfer Pricing Regime

OH

Osler, Hoskin & Harcourt LLP

2023 Tax Dispute Resolution Quarterly Update | Session 1 (Video)

GW

Gowling WLG

Transfer Pricing 2023: Trends & Developments

MT

Miller Thomson LLP

Guide To The Canadian Tax Treatment Of Halal Mortgages: Halal Mortgages Are Shari'ah-Compliant But Taxable In Canada

RS

Rotfleisch & Samulovitch P.C.

Supreme Court To Consider Tax Court Jurisdiction

BL

Borden Ladner Gervais LLP

Black History, Black Futures With Paul Davis And Rob Davis (Podcast)

Canada Commercial

ML

McMillan LLP

The CRA's New Power To Compel Oral Interviews

Canada Accounting

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Davies Ward Phillips & Vineberg

Canada Proposes Significant Tax Amendments To Align With OECD BEPS Recommendations

OH

Osler, Hoskin & Harcourt LLP

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Latest Videos

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2023 Tax Dispute Resolution Quarterly Update | Session 1 (Video)

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Gowling WLG

2022 Tax Dispute Resolution Monthly Update | Session 10 (Video)

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Gowling WLG

A New Look At Risk Characterization (Video)

GW

Gowling WLG

2022 Tax Dispute Resolution Monthly Update | Session 5 (Video)

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Gowling WLG

Accelerating Business | Episode 3 (Video)

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Gowling WLG

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