3 February 2021 Transfer Pricing Webinar of the Canadian Tax Foundation: Panel IV: Selected Topics in Transfer Pricing

S. 247(2.1) ordering rule is clarifying

• S. 247(2.1) effected clarifying amendments. Admittedly, the CRA might have considered the proposed...

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OECD “delineation” of thin cap loan is likely partial recharacterization, which is acceptable

• Paragraph 10.13 of BEPS chapter 10 references a...

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MAP referrals for non-s. 247(2) adjustments

• There is nothing preventing a MAP request relating to a s. 18(1)(a) matter, where that matter...

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Application of s. 247(2) to transactions between non-residents

• Regarding the finding in 2017-0691191C6 that the transfer pricing rules can apply...

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