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

EMG has contributed their 3rd installment of the Canadian chapter (Chapter 7) in the Kluwer Publication.

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By Merv Edwards and Dean Morris, published in the Wolters Kluwer’s “Guide to International Transfer Pricing: Law, Tax Planning and Compliance Strategies” book.

EMG, as one of the contributor to the Wolters Kluwer publication of “Guide to International Transfer Pricing: Law, Tax Planning and Compliance Strategies”, has written the Canadian Chapter (Chapter 7) of the publication.  The pricing of goods and services when transferred, across border, to a … Read more