Canada’s TPM-15 and TPM-16: Throwing Sand in the BEPS Gears
Read our new Transfer Pricing Report article on TPM-15 Intra-group services and section 247 of the Income Tax Act and TPM-16 Role of Multiple Year Data in Transfer Pricing Analyses. This article dwells into some...
Posted by DRTP
On 26 March 2015
Canada: New Notice of Ways and Means Motion on the Table
Nothing about transfer pricing, international tax or corporate tax in this one. But since there is more than that to tax life... From Finance Canada website available here (en français ici): "The NWMM (Notice of Ways...
Posted by DRTP
On 25 March 2015
BEPS Spain: New Rules for Transfer Pricing Documentation Released
On March 18, 2015, the PROYECTO DE REAL DECRETO XX/2015, POR EL QUE SE APRUEBA EL REGLAMENTO DEL IMPUESTO SOBRE SOCIEDADES was released by the Spain government. This document in Spanish which covers the Master file,...
Posted by DRTP
On 24 March 2015
Reactions of the International Chamber of Commerce to UK 2015 Budget: BEPS as Usual
Nothing new to report in the UK 2015 Budget Statement. No legal wording for the diverted profit tax nor the CbC reporting specific requirements was included in the documents. The International Chamber of Commerce had the...
Posted by DRTP
On 23 March 2015
The Federal Court of Appeal’s decision in re Skechers Canada
On March 2, in re Skechers USA Canada Inc. v. Canada (Border Services Agency) 2015 FCA 58, the Federal Court of Appeal (the “Court”) has upheld the December 13, 2013 decision of the Canadian International...
Posted by Stéphane Dupuis
On 20 March 2015