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DRTP is all about transfer pricing, transfer pricing documentation in Canada, Canadian transfer pricing documentation, transfer pricing method in Canada, and Canadian transfer pricing: Transfer pricing in Canada, Canadian Income Tax Act, Section 247, IC 87-2R International Transfer Pricing, Arm’s length principle, Contemporaneous Documentation, 247(4), Base Erosion and Profit Shifting (BEPS), Pacific Association of Tax Administrators (PATA) Transfer Pricing Documentation Package, OECD Transfer Pricing Guidelines, OECD Report on the transfer pricing aspects of business restructurings, OECD Revised discussion draft on transfer pricing aspects of intangibles, OECD Special considerations for intangibles, OECD 2010 Report on the Attribution of Profits to Permanent Establishments, OECD Multi-Country Analysis of Existing Transfer Pricing Simplification Measures, European Commission Joint Transfer Pricing Forum, Transfer Pricing, Transfer pricing in Canada, Landmark transfer pricing court cases, Transfer pricing court cases, International tax cases, DRTP Inc., DRTP Transfer Pricing, TPM-01 – Referrals to the Transfer Pricing Review Committee (Archived), TPM-02 – Repatriation of funds by Non-residents – Part XIII, TPM-03 – Downward Transfer Pricing Adjustments under Subsection 247(2), TPM-04 – Third Party Information, TPM-05 – Contemporaneous Documentation (Archived), TPM-05R – Requests for Contemporaneous Documentation, TPM-06 – Bundled Transactions, TPM-07 – Referrals to the Transfer Pricing Review Committee (Archived), TPM-08 – The Dudney Decision: Effects on Fixed Base or Permanent Establishment Audits and Regulation 105 Treaty-Based Waiver Guidelines, TPM-09 – Reasonable efforts under section 247 of the Income Tax Act, TPM-10 – Advance Pricing Arrangement Rollback (Archived), TPM-11 – Advance Pricing Arrangement (APA) Rollback, TPM-12 – Accelerated Competent Authority Procedure (ACAP), TPM-13 – Referrals to the Transfer Pricing Review Committee, TPM-14 – 2010 Update of the OECD Transfer Pricing Guidelines, Base Erosion and Profit Shifting (BEPS), Transfer pricing in Canada, BEPS Project, BEPS action plan, Exchange of information, Hybrid Mismatch Arrangements, OECD Country-by-country reporting, OECD Country-by-country reporting Template, Tax Treaty, Tax haven, T106 Information Return of Non-Arm’s Length Transactions with Non-Residents, Guidelines for Treaty-Based Waivers Involving Regulation 105 Withholding; IT177R2 Permanent Establishment of a Corporation in a Province, IC75-6R2 Required Withholding from Amounts Paid to Non-Residents Providing Services in Canada, IC77-16R4 Non-Resident Income Tax, RC17 Taxpayer Bill of Rights Guide: Understanding Your Rights as a Taxpayer, OECD Model Tax Convention, Mutual Agreement Procedures, Advance Pricing Arrangements (APA), IC94-4R Advance Pricing Arrangements (APA), IC94-4RSR Advance Pricing Arrangements for Small Businesses, IC71-17R5 Guidance on Competent Authority Assistance Under Canada’s Tax Conventions, Memorandum of Understanding Between The Competent Authorities of Canada and The United States of America, Arbitration, Arbitration Board Operating Guidelines – Canada – United States, Transfer pricing in Canada, 23A Exemption Method, 23B Credit Method, Article 25 Mutual Agreement procedure, Double taxation relief, Carrying on a business in Canada, Permanent establishment (PE), Canada Revenue Agency (CRA), Section 1.482, Section 482, Code of Federal Regulations, Internal Revenue Code, IRS, Section 1.6662, Section 6662, 1.482-1 – Allocation of income and deductions among taxpayers, 1.482-2 – Determination of taxable income in specific situations, 1.482-3 – Methods to determine taxable income in connection with a transfer of tangible property, 1.482-4 – Methods to determine taxable income in connection with a transfer of intangible property, 1.482-5 – Comparable profits method, 1.482-6 – Profit split method, 1.482-7 – Methods to determine taxable income in connection with a cost sharing arrangement, 1.482-8 – Examples of the best method rule, 1.482-9 – Methods to determine taxable income in connection with a controlled services transaction, Transfer pricing in Canada, Intercompany transaction, Guarantee fees, Management fees, Intragroup services, Shareholder activity, Stewardship activity, Stewardship costs, Duplication of services, Ancillary services, Shared services, « On Call » services, Direct-charge method, Indirect-charge method, Cash pooling arrangement, Cost pooling Arrangement, Cost pooling Agreement, Global trading, Cost center, Profit center, Value chain, License Fees, Intangible, Intangible Property (IP), Intellectual property (IP), Commercial intangibles, Marketing intangibles, Cost Contribution Arrangements, Cost-sharing Agreement, Tax planning, Business restructuring, FAPI, Thin capitalisation, full-fledged distributor, full-fledged manufacturor, Entrepreneurial risk, Contract manufacturer, Consignment, Work for hire, Limited-risk distributor, Low-risk distributor, Routine distributor, Limited-risk manufacturer, Low-risk manufacturer, Routine manufacturer, Location savings, Royalty, Base Erosion and Profit Shifting (BEPS), Risk management for transfer pricing, Comparability analysis, Transfer pricing method, Transfer pricing in Canada, Comparability search, Characteristics of property or services, Functional analysis, Contractual terms, Economic circumstances, Business strategies, Functions, Risks, Assets, Best method rule, Traditional transaction method, Comparable uncontrolled price method (CUP), Resale price method, Cost plus method, Transactional profit method, Transactional net margin method (TNMM), Transactional profit split method, Contribution analysis, Residual analysis, Allocation keys, Tested party, Internal comparable, External comparable, Comparability adjustment, Arm’s length range, Interquartile range, Profit level indicator (PLI), Berry Ratio, Comparable profit method (CPM), Base Erosion and Profit Shifting (BEPS), Transfer pricing audit, Transfer pricing in Canada. DRTP is all about transfer pricing Base erosion and profit shifting initiative (BEPS), Master file, Local file and Country-by-Country reporting services by DRTP: Assessment of tax risks for transfer pricing purposes, Management of tax risks for transfer pricing purposes, Analysis, recommendations and implementation of transfer pricing policies and procedures, Analysis, recommendations and implementation of transfer pricing documentation, Analysis, recommendations and implementation of value chain management, Relevance of advance pricing arrangements (APA), Consulting on advance pricing arrangements (APA), Documentation for advance pricing arrangements (APA); Transfer pricing documentation services by DRTP: Preparation of transfer pricing documentation, Assembling of transfer pricing documentation, Analysis of transactions, Economic analysis, Comparability analysis optimization, Functional analysis optimization, Functions valuation for transfer pricing purposes, Risks valuation for transfer pricing purposes, Assets valuation for transfer pricing purposes, Transfer pricing method optimization, Optimized search for comparables, Transfer pricing economic study and report; Transfer pricing tax relief, dispute resolution and litigation services by DRTP: Consulting through the CRA and IRS transfer pricing audit stage, Consulting through the CRA and IRS objection and appeal process, Consulting through the Competent Authority process, Economic expert study and report for the CRA and IRS objection and appeal process, Transfer pricing economic study and report for the objection and appeal process, Transfer pricing economic study and report for tax litigation, Transfer pricing economic expert-witness for tax litigation; Transfer pricing policies and risk management services by DRTP: Assessment of tax risk for transfer pricing purposes, Management of tax risk for transfer pricing purposes, Assessment of transfer pricing policies and procedures, Design of transfer pricing policies and procedures, Implementation of transfer pricing policies and procedures, Evaluation of transfer pricing policies and procedures; Advance Pricing Arrangements (APA) services by DRTP: Analysis of transactions, Comparability analysis, Relevance of advance pricing arrangements (APA), Consulting and documentation on advance pricing arrangements (APA): prefiling meeting, request, submission, documentation, site visits, economic study and report, transfer pricing report, Design and assembly of advance pricing arrangements (APA) request, Design and assembly of advance pricing arrangements (APA) submission, Economic expert study and report for advance pricing arrangements (APA) submission; Value chain management for transfer pricing services by DRTP: Function valuations and strategic location, Risk valuations and strategic location, Asset valuations and strategic location, Intangible valuation and strategic location, Intragroup service valuations and strategic location, Financial transaction (guarantee fees, insurance, cost and cash pooling, etc.) valuation and strategic location, Business restructuring. Canada Revenue Agency Audit Manual : Chapter 15 International Audit Issues, Income of a Non-resident, Part XIV Tax, Income Earned in Canada from an Office or Employment, Income from Business Carried on in Canada, Extended meaning of “Carrying on Business in Canada”, Disposition of Taxable Canadian Property by a Non-Resident, Part XIII Tax on Income from Canada of Non-Resident Persons, Withholding and Reporting Obligations of the Payer, Residency, Residency of Corporations, Foreign-Based Information and Documentation, Requirement to Provide Foreign-Based Information, Permanent Establishment, Foreign Reporting Requirements, T1134-A and T1134-B, T1134 Information Returns (Foreign Affiliates), T1135 Returns (Foreign Income), T1141 Returns (Transfers, Loans to Non-Resident Trusts, T1142, Non-resident Trusts, Offshore Trusts, Non-Arm’s Length Transactions with Non-Residents, T106 Risk Assessment, 15.9.0 Transfer Pricing, Tax Havens Audit Guide, NR4, Tax Treaties, The Income Tax Conventions Interpretation Act, General Anti-Avoidance Rule (GAAR), Relief from Double Taxation, Income from Real Property (or Immovable Property), Business Profits, Capital Gains, International Tax Services. This company is about transfer pricing documentation Canada, transfer pricing penalty Canada, transfer pricing methodologies Canada, transfer pricing methods Canada, transfer pricing documentation Canada, transfer pricing rules Canada, transfer pricing tax, transfer pricing cup method, transfer pricing cup method Canada, transfer pricing transactional net margin method TNMM, transfer pricing transactional net margin method TNMM Canada, OECD transfer pricing guidelines, transfer pricing profit split method, transactional profitmMethods, transfer pricing intangible, operational transfer pricing, transfer pricing policies and procedures. DRTP assists with treaty-based requests, returns and waivers such as non-resident Canadian income tax matters, residency or residence matters, permanent establishment matters, transfer pricing adjustments, double taxation of income from real property or business profits, tax withheld (withholding) on dividends, interests, royalties, management fees, services provided by non-residents, income from real property, issues on income from interest or related to capital gains, double taxation arising on income from employment, pension and annuities, Part XIII Tax withholding under the Canadian Income Tax Act, Regulation 102 and regulation 105 withholding waivers, double taxation on other types of income and Foreign tax credit matters.

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