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.-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 Narrowness of U.S. ...

", Canadian Tax Journal, (2013) 61:1, 159-78, at 172-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 After noting (at p. 171) that "the arm's length principle...tries to hypothesize its way around the economic integration of the firm," he stated: Treating the firm's constituent and inextricable parts as if the composite entity were merely the sum of discrete transactions and dealings between independent actors is not a mere peccadillo. ...

Matias Milet, Jennifer Horton, "The Canada Revenue Agency’s Interpretation of the 2017 OECD Transfer Pricing Guidelines", International Tax (Wolters Kluwer CCH), No. 103, December 2018, p.10-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 The OECD 2017 Transfer Pricing Guidelines reoriented transfer pricing towards the concept of value creation, namely, of ensuring that profits are taxed where economic activities take place and value is created. ...

Goguen, "Recharacterization of Transactions Under Section 247: Still an Exceptional Approach", 2018 Conference Report (Canadian Tax Foundation), 21:1-25-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 2017 OECD transfer-pricing guidelines mandate an “accurate-delineation approach” that is contrary to s. 247(2) The approach taken in the 2017 OECD Guidelines of “accurately delineating” a transaction is, in fact, an approach of departing from the contracts and characterizing the cross-border transaction in accordance with its economic substance. ...

Hetal Kotecha, "Canadian Tax Concerns Arising from the Use of Professional Employer Organizations", International Tax Highlights (IFA), Vol. 3, No. 3, August 2024, p. 9-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 What is a PEO? ...

Ault, "Some Reflections on the OECD and the Sources of International Tax Principles", Tax Notes International, 17 June, 2013, p. 1195-- summary under Article 25 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 25 After referring to the 1998 release by the OECD of a report on harmful tax competition that signaled an important change of focus in international cooperation efforts and to the OECD's base erosion and profit shifting (BEPS) project, he considered the following case. ...

Durst, "The OECD Discussion Draft on Transfer Pricing for Intangibles", Viewpoints, Tax Notes International, 30 July 2012, p. 447:-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 After quoting (at p. 448) the statement in the OECD discussion draft on transfer pricing for intangibles that "neither legal ownership, nor the bearing of costs related to intangible development... entitles an entity within an MNE group to retain the benefits or returns with respect to intangibles," Durst states: For decades, many have apparently believed erroneously that under generally applicable principles of international tax law, bearing the financial costs of business activities entitles a party, for tax purposes, to income derived from those activities. ...