Corporate Taxes, Transfer Pricing, Canada

UK Tax Round Up - February 2025

Proskauer Rose LLP on 3/10/2025

Welcome to February’s edition of the UK Tax Round Up. This month has seen a number of interesting decisions covering the unallowable purpose test in relation to cross border group relief tax losses, the application of the...more

Transfer Pricing in the Time of COVID-19

Bennett Jones LLP on 2/9/2021

Many Canadian businesses have closed the books on their 2020 fiscal year, having faced an unprecedented economic shock wrought by the pandemic. 2020 fiscal year results will undoubtedly be affected, in many cases to the...more

International Tax Treaty: Canada

Freeman Law on 11/6/2020

Quick Summary. In 1867, the United Kingdom passed a Parliamentary act establishing what is now known as Canada. Today, Canada, the largest country in the Western Hemisphere, is a federation of ten provinces and three...more

Loans to U.S. Subsidiaries Should Be Carefully Structured and Documented to Obtain U.S. Tax Benefits

Dorsey & Whitney LLP on 8/18/2017

Canadian companies should carefully structure and document loans and advances to their U.S. subsidiaries. If loans to U.S. subsidiaries are not properly structured and documented, such loans may be recharacterized as equity...more

Is Your Customs Compliance BEPS Ready?

Bennett Jones LLP on 2/9/2017

2016 was the first year of the new transfer pricing reporting regime called Country-by-Country Reporting (CbCR). It will be a major new tool for revenue authorities and will undoubtedly lead to greater audit activity and more...more

CRA Releases Important Transfer Pricing Guidance on Management Fees and Other Intra-Group Services

Bennett Jones LLP on 2/25/2015

CRA recently released a new Transfer Pricing Memorandum (TPM-15) giving detailed guidance on CRA’s audit approach to management fees and other charges for intra-group services, including on allocation keys for indirect...more