Transfer Pricing

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
Practice

Limits on oral interviews confirmed in Cameco

Be careful what you ask for, says John A. Sorensen of Gowling WLG