Canada–MNE Tax

Americas

Dow Chemical and Canada’s transfer pricing dispute: litigating pennies while ignoring a large toll manufacturing issue

January 12, 2021

Dr. J. Harold McClure, a New York City economist, discusses the Tax Court of Canada’s December 18 decision in the Dow Chemical transfer pricing case, noting that the parties did not address a potential toll manufacturing issue . . .

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Americas

Canada’s bolder stance on unilateral digital taxes likely prompted by reduced fear of tariffs in Biden administration: Andy Blatchford / Politico→

December 15, 2020

Americas

Canada to propose digital tax, extend GST/HST laws to nonresident businesses

December 1, 2020

The Canadian government has announced that it will propose a new tax on multinationals that provide digital services . . .

Americas

Uranium transfer pricing and Cameco’s battle with Canada

November 11, 2020

New York City economist, Dr. Harold McClure, notes the Canada Revenue Agency’s recent decision to file an appeal in the Cameco transfer pricing dispute and suggests that prices paid by Cameco’s Swiss affiliate to its Canadian mining affiliate for uranium may not be arm’s length . . .

Americas

Canada Revenue appeals long-running transfer pricing dispute loss to Supreme Court

November 3, 2020

The Canada Revenue Agency (CRA) has filed an appeal in the Supreme Court of Canada seeking to overturn its June 26 loss . . .

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Americas

AgraCity’s Canada transfer pricing dispute: co-distribution and the markup for logistics

September 2, 2020

Dr. Harold McClure, a New York City economist, discusses key transfer pricing issues in the Tax Court of Canada’s August 27 ruling in AgraCity Ltd. v. the Queen, including issues involving co-distribution and the appropriate benchmarking for a logistics affiliate . . .

Americas

First look: AgraCity and Saskatchewan Ltd. prevail in Canada transfer pricing dispute

September 1, 2020

The Tax Court of Canada, on August 27, ruled in favor of Candian company AgraCity Ltd. and related company, Saskatchewan Ltd., in a dispute with the Canadian Revenue Agency over . . .

Africa

Intercompany interest deductions in the extractive sector

July 15, 2020

Economist Dr. Harold McClure of New York City discusses the taxation of intercompany financing in the extractive sector, focusing on likely tax disputes concerning the financing of Australia’s Gorgon natural gas project, the UN’s recent guidance on transfer pricing in the extractive sector, and the ConocoPhillips and Chevron intercompany financing litigations . . .

Americas

Canada Appeals Court rules in Cameco’s transfer pricing dispute involving Swiss subsidiary

July 14, 2020

Warren Novis, Head of Transfer Pricing at BDO, Ireland, discusses the Canada Federal Court of Appeal’s decision in Cameco, a long-standing transfer pricing dispute . . .

Americas

First look: Cameco Corp. prevails in landmark in transfer pricing case

July 1, 2020

On June 26, Canada’s Federal Court of Appeal ruled in favor of Cameco Corporation in the transfer pricing . . .

Americas

Canada-Madagascar tax treaty enters into force: Government of Canada→

June 24, 2020

Americas

Canada addresses COVID-19 travel restrictions’ effect on tax residency, PEs: KPMG→

May 27, 2020

Americas

Canada defers payment of income tax for businesses, defers SME audits, in response to COVID-19: Government of Canada→

March 20, 2020

Americas

Canada’s liberal party proposes three percent digital services tax on advertising, intermediation

October 2, 2019

Canadian Prime Minister Justin Trudeau’s Liberal Party has proposed in its reelection platform . . .

Americas

France joins ICAP pilot to jointly assess MNE tax positions

September 18, 2019

France has joined the International Compliance Assurance . . .

Americas

Canada and Switzerland deposit BEPS MLI ratification documents with OECD

August 29, 2019

Canada and Switzerland have deposited their instruments of ratification for the . . .

Americas

OECD releases “stage 2” reports on tax dispute resolution in US, UK, Belgium, Switzerland, Canada, Netherlands

August 14, 2019

The OECD on August 13 published six “stage 2” peer review reports assessing whether the United States, United Kingdom, . . .

Asia-Pacific

G7 finance ministers agree on some features of international tax rewrite

July 18, 2019

G7 finance ministers, at their meeting in Chantilly, France on July 17–18, agreed to several aspects of a revised system for taxing multinationals. According to the ministers, the international tax and transfer pricing rules . . .

Americas

Canada ratifies BEPS MLI to fight tax avoidance by multinationals

June 24, 2019

Canada has ratified a multilateral tax treaty developed by more than 100 countries that is designed . . .

Americas

Canada speeding up completion time for advance pricing agreements, report shows

August 6, 2018

Kabir Jamal of Goodmans LLP, Toronto, discusses Canada’s 2017 advance pricing agreement report, which reveals improvements in the operation of this government program designed to provide multinational taxpayers with certainty regarding their prospective transfer pricing transactions . . .

Canada

What the UK’s new transfer pricing and diverted profits tax statistics tell us

August 1, 2018

Liz Hughes, a partner with Grant Thornton UK LLP, discusses the UK’s 2017–18 transfer pricing and diverted profits tax statistics, released July 31, noting several interesting trends . . .

Americas

Canadian Tax Court rules income from grocery firm Loblaw’s Barbadian banking subsidiary was taxable foreign accrual property income: BNN Bloomberg→

September 10, 2018

Americas

Court rules Canadian tax authority can’t question executives in Cameco transfer pricing case: Drew Hasselback / Financial Post→

August 17, 2017

Americas

Canada takes conservative approach to multilateral instrument: Gowling WLG→

June 15, 2017

Americas

Canada releases draft tax legislation to implement 2016 budget proposals

August 5, 2016

Kabir Jamal, an attorney with Goodmans LLP, Toronto, reports that the Canadian government has just released for consultation draft tax proposals to implement measures in Budget 2016 . . .

Americas

Canada to require 2016 CbCR constituent entity filing for Canadian subs parented in countries without exchange agreement: PWC→

January 9, 2018

Americas

Canada to negotiate tax treaties with Germany and Switzerland

June 15, 2017

Canada’s Department of Finance on June 7 announced in separate releases that it will commence tax treaty negotiations with . . .

Africa

New CIAT database tracks BEPS implementation in 36 countries

February 22, 2019

The Inter-American Center of Tax Administrations (CIAT) on February 21 released . . .

Americas

Canada, Israel sign tax treaty, text available

October 6, 2016

The governments of Canada and Israel signed a new tax treaty on September 21, Canada’s Department. . .

Americas

Australia may exercise transfer pricing reconstruction power, will change approach to allocation of risk, official says

August 22, 2018

The Australian Taxation Office has not yet used its sweeping power to reconstruct transactions for transfer pricing purposes; however, that may soon change, Australian Deputy Commissioner Mark Konza said at the Tax Institute’s 2018 National Transfer . . .

Americas

Canada Federal budget 2017 proposes base erosion rule for foreign branches of life insurers

March 22, 2017

Canada’s Federal budget 2017, released today, proposes to amend the Income Tax Act to prevent income from the insurance of Canadian risks from being shifted to a foreign branch of a Canadian life insurer . . .

Africa

Multinationals asked to assess MAP tax dispute resolution in US, UK, Belgium, Canada, Netherlands, Switzerland

October 31, 2016

The OECD has today asked international business to report grievances about the mutual agreement procedure (MAP) for resolving cross-border tax disputes in the US, UK, Belgium, Canada, Netherlands, and Switzerland. The OECD seeks responses to a . . .

Americas

More multinationals applying for US advance pricing agreements, statistics show

March 31, 2016

The US IRS on March 31 released statistics on the performance of the IRS’s Advance Pricing Mutual Agreement Program (APMA), revealing that taxpayers submitted . . .

Americas

Canadian appeals court overturns decision in Univar, concludes GAAR does not apply to paid-up-capital planning during acquisition: EY→

October 23, 2017

Africa

US has agreed to country-by-country tax info exchange with 11 countries, OECD says

June 22, 2017

The United States has so far put in place 11 bilateral competent authority arrangements for the automatic exchange of country-by-country reports, the OECD reported a June 22 release. The US now has . . .

Switzerland and Canada agree on automatic exchange of financial account information

February 5, 2016

Switzerland and Canada on February 4 signed a joint declaration to work toward implementing automatic exchange of information on the financial accounts . . .

Americas

Wolrige Mahon to expand to Toronto, hires Kemp and Sinclair

January 31, 2018

Vancouver-based Baker Tilly member firm, Wolrige Mahon LLP, on January 22 announced that it will expand its offices to Ontario, hiring John Sinclair and David Kemp to lead a new Toronto operation offering . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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