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
Businesses are invited to participate in an international survey from the OECD to measure the impact of tax uncertainty on their investment decisions. Companies have until December 16 to participate in a confidential...more
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
I spoke recently on a panel in Tokyo on the future of international tax planning after BEPS (the OECD’s & G20’s Action Plan to counter Base Erosion & Profit Shifting). The panel also featured a senior official at the OECD and...more
The OECD proposes to reform transfer pricing documentation for multinational enterprises and to impose onerous country-by-country (CbC) reporting obligations, including disclosure of taxes paid in each country in which a...more
The Supreme Court of Canada recently endorsed a fundamental principle in Canadian tax law – namely that absent sham or statutory recharacterization rules, “tax law applies to transactions governed by, and the nature and legal...more
The OECD released its Action Plan on Base Erosion and Profit Shifting (BEPS) on Friday. The BEPS initiative was launched earlier this year at the request of the G20 to counter alleged abuses by multinational corporations to...more
At the OECD International Tax Conference in DC on June 3 and 4, Joe Andrus, Head of the OECD’s Transfer Pricing Unit, announced that the OECD’s Discussion Draft on Intangibles released in 2012 is under revision in two key...more
The OECD recently issued a report targeting corporate tax planning and transfer pricing strategies, which it asserts constitute a serious risk to tax revenues, tax sovereignty among nations and tax fairness. (OECD (2013),...more