Global Transfer Pricing Updates of Note: India’s challenge of Marketing Intangibles: Intangible property is often the most valuable component of a multinational enterprise (MNE). The identification and valuation of intangible property are key components in the determination and documentation of an MNE’s transfer pricing policy. … Read more

OECD Draft Handbook  On April 30th, 2013, the OECD released the “Draft Handbook on Transfer Pricing Risk Assessment”. The handbook is a resource to develop risk assessments which assists tax authorities in the assignment of appropriate audit resources that reflects the nature and amount of … Read more

North American Revival of the Advance Pricing Agreement Program Recent public statements from the Canada Revenue Agency (“CRA”) and the US Internal Revenue Service (“IRS”) confirm there have been significant improvements in the administration of the Advance Pricing Agreement (“APA”) Program. Richard McAlonan, director of … Read more

Canada Revenue Agency’s Responses from Tax Executive Institute Questions The Tax Executive Institute (“TEI”) recently published written responses from their annual liaison (held on December 4-5, 2012) with the Canada Revenue Agency (“CRA”). Click here  Of note are the questions related to transfer pricing: Question 10 … Read more

Guarantee Fees: The recent Canadian litigation of GE Capital and the controversial 2010 Taxation Ruling in Australia, TR 2010/7 brought global attention in respect of the treatment of related party cross-border guarantee fees. Unfortunately, the litigation and tax ruling did not significantly reduce this uncertainty in … Read more