If you are operating a business across borders, you know that international business is rewarding but complex. One of the key areas you'll need to manage carefully is transfer pricing, which is the practice of setting prices for goods, services or intangible assets...
Transfer Pricing
3 arm’s length principle issues that can arise
International transactions between related businesses can be highly complex matters. If your business is a taxpayer for Canadian tax purposes, you can run into some complicated issues regarding the arm's length principle. Misunderstanding arm's length The arm's...
What the global tax rate means for Canadian companies
Recently, over 130 countries reached an agreement regarding a global corporate tax. These efforts aim to prevent corporations from shifting tax revenues and profits from countries with lower tax rates, keeping them in their home countries. This change will affect...
Are transfer pricing disputes getting easier to resolve?
Tax laws are incredibly complicated - especially when it comes to international tax laws. Navigating these matters takes considerable financial knowledge as well as legal acumen. Because of how complex these cases are, they can take a long time to resolve. Rarely are...
The basics of the law, the guidelines, the circulars, the TPMs, and how they relate to Canadian transfer pricing
An understanding of the nature and significance Provisions of Canadian law, the OECD guidelines (Guidelines), and the administrative circulars and memoranda of the Canada Revenue Agency (CRA) as set forth in Circulars and Transfer Pricing Memorandums (TPM) is critical...
Post BEPS Transfer Pricing
Shaun MacIsaac commented on current post- BEPS issues including the new landmark Chevron case ... Shaun T. MacIsaac, Q.C. appeared with a panel of international experts at the Sofitel Hotel, London, UK on November 22, 2017, and provided comments that related to the...
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PMR Law have been named the winner of the Business Law Firm of the Year 2017 Canada by CV Magazine and the Global 100 Excellence Award as Firm of the Year (Litigation Counsel) Canada. These awards are much appreciated by the firm. In everything we do, we strive to provide the best service for our clients.