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Economic uncertainty produces various challenges for businesses, some of which are more obvious and urgent than others.

Relevant to: Multinational groups with Canadian subsidiaries or a Canadian parent corporation, and other Canadian residents who engage in transactions with non-residents of Canada...

Transfer pricing involves the price that one member of a multinational firm charges another for goods, services and intangible assets transferred between related parties. The central theme in transfer pricing is to ensure that the prices at which these goods, services and intangible assets are transferred represent arm's length standards.

Base erosion and profit shifting have recently made news headlines around the world.

Prompted by government concerns about the depletion of Canada’s tax base, tax authorities here are now using transfer pricing principles as a primary audit tool to evaluate – and challenge – income allocation to Canada by multinationals. As a result, virtually all cross-border business activities between related parties are now subject to transfer pricing audits. Here, we look at some of the key areas tax authorities are zeroing in on.

In October 2015, OECD released its BEPS Action 13, focused on new country-by-country (CbC) reporting requirements for large multinational enterprises (MNEs).

Finally, the FCA examined the legislative history of the provision.

Businesses that operate globally continue to face complex tax issues, and transfer pricing – the practice of establishing arm's-length prices for related-party cross-border transactions – has become more important than ever.

When a Canadian or U.S.-based multinational finds itself under audit, the taxpayer and the tax authority are often at odds over what documentation is subject to disclosure and what remains beyond the prying eyes of the tax authority.

The Canada Revenue Agency ("CRA") has been steadily increasing the intensity of audits targeting cross-border investment and business activity.

The OECD has recently released its Action Plan on Base Erosion and Profit Shifting.

Since the introduction of the Transaction Value System of customs valuation by Canada on January 1, 1985, the Canada Border Services Agency (CBSA) has maintained a stated policy of denying refund claims of related party importers who seek to amend declared values for duty to account for adjustments that decrease transfer prices after importation.

Businesses are invited to participate in an international survey from the OECD to measure the impact of tax uncertainty on their investment decisions.

The timing of revenue recognition may need to change in the near term for a construction entity preparing IFRS financial statements.

The transfer of real property is subject to a land transfer tax in most, but not all, provinces in Canada

The Tax Court of Canada has ruled in favour of Cameco in its massive tax dispute with the Minister of National Revenue.

On June 6, 2023, the Department of Finance released a consultation paper on Canada's transfer pricing rules.