Perspective
30 Sep 2021
Transfer pricing alert archive
Transfer pricing alerts on important tax developments informing companies on how to reduce risks and resolve disputes efficiently.
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2021
- September 28, 2021: CRA releases revised IC71-17R6 – Competent Authority Assistance under Canada’s Tax Conventions
- February 24, 2021: Supreme Court of Canada dismisses the Canada Revenue Agency’s application for leave to appeal in the Cameco Corporation ongoing tax dispute
- January 25, 2021: GRI 207: Tax disclosures in sustainability reporting
- January 14, 2021: What does Pillar One mean for corporate Canada?
2020
- December 1, 2020: Tax Court rules in favour of taxpayer in a transfer pricing case
- April 7, 2020: Cancellation of IC87-2R
2018
- October 30, 2018: Cameco wins landmark transfer pricing case
- August 9, 2018: OECD releases discussion draft on transfer pricing of financial transactions
- July 20, 2018: Advance Pricing Arrangement Program Report 2017
- March 19, 2018: Canada extends reassessment periods and increases CRA funding
2017
- December 5, 2017: OECD releases updated transfer pricing country profiles
- November 27, 2017: Advance Pricing Arrangement Program Report 2016
- April 4, 2017: Additional guidance on Canada's country-by-country reporting requirement
- February 6, 2017: Canada’s country-by-country legislation comes into force, CRA releases Form RC464
2016
- September 15, 2016: BEPS update – draft documents released for public review
- August 3, 2016: Canada releases draft legislation for country-by-country reporting
- March 30, 2016: CRA guidance on the impact of government assistance on transfer prices
- March 23, 2016: Canada announces proposed country-by-country reporting requirements
- February 11, 2016: Federal Court of Appeal upholds Tax Court of Canada decisions in Marzen
2015
- October 15, 2015: Final report on BEPS Actions 8-10: Guidance for applying the arm’s length principle (including risk and recharacterization)
- October 7, 2015: OECD releases final BEPS reports
- July 31, 2015: Changes to transfer pricing Guidelines
- April 15, 2015: Transfer pricing documentation changes are inevitable
- February 23, 2015: The CRA provides additional guidance on treatment of intra-group services
- February 19, 2015: Canada updates guidance on role of multiple year data in transfer pricing analyses
2014
- February 26, 2014: Federal Court of Appeal upholds the Canada Revenue Agency’s request for foreign-based information
- February 25, 2014: Customs and transfer prices - Skechers v. CBSA
2012
- October 19, 2012: Supreme Court of Canada hands down partial victory for GlaxoSmithKline, but saga continues
- April 26, 2012: Intercompany contingent liability payments: staying well-armed
- April 2, 2012: Federal budget 2012: clarity on transfer pricing secondary adjustments and repatriation
- January 24, 2012: Supreme Court of Canada hears GlaxoSmithKline case: focuses on business reality concept
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