Technical Transfer Pricing Tip Transfer Pricing: How BEPS has increased the importance of Intercompany Legal Agreements Transfer pricing has been a predominant focus within the OECD’s work of base erosion and profit shifting (BEPS) and the modernization of the international framework for taxing multinational companies. … Read more

Technical Transfer Pricing Tip Can there be different transfer pricing policies between different related parties for a similar transaction? Does this change with the OECD revised transfer pricing documentation standard?  A consistent transfer pricing policy occurs when the identical policy is followed for similar transactions … Read more

Four Notable 2014 Canadian Transfer Pricing Developments:    1. Revised Canadian Revenue Agency (“CRA”) Transfer Pricing Memorandum 05 – Requests for Contemporaneous Documentation:  Key Points raised in the revised Transfer Pricing Memorandum include: Greater emphasis on the fact that auditors must issue, without discretion, a … Read more

OECD Meetings: On November 12th and 13th, 2013 the OECD held a public consultation on transfer pricing topics in Paris. The meeting was attended by delegates from more than 35 countries and by more than 150 individuals including representatives from business and government. The topics … Read more

An Improvement but Canada still Lags the Pack:  Canada Revenue Agency (CRA) Releases their 10th Annual Report on the Mutual Agreement Procedure (MAP) Program.   The recently released annual MAP report provides good news for Canadian taxpayers that are in the MAP program, or is considering … Read more