Transfer Pricing

Thought Leaders

The latest Canadian tax scam has a Caribbean flavour

Allan Lanthier looks at the BVI Switch tax avoidance scheme used by wealthy Canadians and what action could be taken by the federal finance minister
Thought Leaders

Alta Energy: Has the GAAR become toothless? – Part II

In part two of his two-part series, Allan Lanthier highlights areas of the Supreme Court's Alta Energy decision that are open to vigorous debate
Thought Leaders

Alta Energy: Has the GAAR become toothless? – Part I

In part one of a two-part series, Allan Lanthier looks at the details of the Alta Energy tax avoidance decision by the Supreme Court of Canada
Thought Leaders

Pandora Papers: “It’s time to pursue lawyers and accountants who enable tax evasion” – offshore tax expert Q&A

Professor Ronan Palan on the repercussions of the Pandora Papers
Thought Leaders

Global minimum corporation tax rate: why the argument that it breaches EU law will probably fail

But legal argument just one obstacle towards implementation says Professor Rebecca Parry
Thought Leaders

G7 tax deal: if you think multinationals will be forced to pay more, you don’t understand tax avoidance

Anticipate new accounting ways around the rules, says Professor Ronen Palan
Transfer Pricing

Common misperceptions about the G7 global corporate tax rate pact

Popping some media inaccuracies about the G7 two-pillar framework with Canadian tax lawyer and accountant David J Rotfleisch
Transfer Pricing

Canadian budget proposes new cross-border interest deductibility limit

Jared A. Mackey, Brendan Sigalet and Philip B. Ward of Bennett Jones LLP on a fundamental change to the existing interest deductibility regime
Transfer Pricing

Key takeaways from Supreme Court's termination of Cameco transfer pricing saga

The gulf will continue to grow between Canadian tax law and OECD Transfer Pricing Guidelines, says Steve Suarez of Borden Ladner Gervais LLP
Transfer Pricing

Transfer pricing in the time of COVID-19

How the consequences of COVID-19 impact TP reporting and compliance is complex, say Claire M.C. Kennedy and Hennadiy Kutsenko of Bennett Jones
Transfer Pricing

AgraCity Ltd. v. The Queen, case study

Will recent CRA tax court losses result in the toughening of transfer pricing rules?
Transfer Pricing

Transfer pricing & APA considerations during an economic disruption

Mark Kirkey of Gowling WLG on transfer pricing in the new economic reality