27 March 2019 CTF Seminar - Transfer Pricing

Policy Tabs

Summaries

Summary Under

downward-adjustment requests reviewed for whether there is double non-taxation

S. 247(10) states that a downward adjustment shall not be made unless it is “appropriate in the circumstances.” How is this discretion...

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Summary Under

3-step process before s. 247(2)(d) is applied

In practice, where CRA concludes that there should be recharacterizion under ss. 247(2)(b) and (d), it considers itself to be implicitly finding...

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Summary Under

use of CbC reports for assessing risk

Canada has committed to the “appropriate use” of CbC reporting, namely, its use in assessing risk in transfer-pricing and other BEPS-related...

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Summary Under

access to tax accrual working papers only where necessary

BP is not a complete bar to access tax accrual working papers, as indicated by Atlas. The Communiqué contemplates reasonableness and restraint....

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