Transfer Pricing
Practice
Expansion of the mandatory disclosure rules in the context of ordinary commercial and routine tax planning transactions
Greg Farano of Gardiner Roberts LLP on the new MDRs, broad enough at first to apply to ordinary commercial and routine tax planning transactions
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- VIEWS 160
Transfer Pricing
Royal Bank Of Canada: A common sense approach to tax treaty interpretation
Michael Hunt and Steven Wenham of Herbert Smith Freehills LLP explain a transfer pricing ruling in the UK Supreme Court in favour of RBC and an oil exploration loan
- COMMENTS 13
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- VIEWS 160
Thought Leaders
The Revenue Rule In Tax Law
Vern Krishna of TaxChambers LLP on the history of international tax and trade law
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- LIKES 149
- VIEWS 160
Practice
The CRA's new power to compel oral interviews
To delineate the limits to its new power, the Canada Revenue Agency should adopt these best practices for audit interviews, argue three tax lawyers from Davies
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- VIEWS 160
Thought Leaders
Corporation tax: Why plans to set a global rate are too complicated and need a new approach
The multilateral plan for a global minimum corporate tax is too complex to work. The OECD should adopt minilateralism instead
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- VIEWS 160
Taxation
Canada confirms intention to institute new interest and deductibility rules
Marc Pietro Allard and Marc André Gaudreau Duval of Davies on the implications of new excessive interest and financing expenses limitation rules
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- VIEWS 160
Taxation
Canada among low corporate tax jurisdictions as global average falls
New trend of rising rates has already begun, says international accounting network
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- VIEWS 160
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
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- VIEWS 160
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
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- VIEWS 160
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
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- VIEWS 160
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
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- VIEWS 160
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
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- LIKES 149
- VIEWS 160