TAX COMPLIANCE & DISPUTE MANAGEMENT

In the last 15 years, every country has implemented new transfer pricing rules aligned of the OECD Transfer Pricing Guidelines. Transfer pricing compliance costs are rising as the BEPS initiative effects are felt all over the world.

This landscape has created more and more tax audit activities and tax litigation. More than ever, state-of-art expertise is required to thrive in this new environment.

 


 

DRTP Consulting services are relevant to any business requiring tax litigation management services. DRTP Consulting services are also relevant to accounting and legal firms which assist their clients with transfer pricing, tax treaties and other international tax matters.

Tax relief, dispute and litigation management

Tax audit activities have substantially increased all around the world in the last 10 years. Tax litigation issues have followed suit. DRTP Consulting can assist with the following tasks:

  • Consulting through the CRA and ARQ audit stage
  • Consulting through the CRA and ARQ objection and appeal process
  • Voluntary disclosures
  • 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
  • Requests to the Appeals division or the Competent Authority
  • Mutual agreement procedure
  • Treaty-based requests, returns and waivers
  • Double tax relief consulting
  • Economic studies and database searches
  • 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 documentation

DRTP Consulting performs all the steps necessary for transfer pricing documentation. DRTP Consulting assist clients establish functional and economic analyses of their intercompany transactions, covering every type of transactions:

  • Tangible good transactions
  • Intangible property transactions
  • Intragroup service transactions
  • Financial transactions such as intercompany loans, guarantees, cash pooling, etc.
  • Cost contribution arrangements

Transfer pricing policies and risk management

With the base erosion and profit shifting initiative (BEPS) now entering its final stage, strong operational transfer pricing is more than ever required to address the heightened compliance requirements. DRTP Consulting can assist with the following tasks:

  • 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
  • Economic studies and database searches for transfer pricing policies and procedures

Treaty-based requests, returns and waivers

Numerous related matters may arise from or independently from transfer pricing. These are treaty-based matters that must be addressed to provide relief of double taxation. DRTP Consulting provides services on treaty-based requests, returns and waivers including:

  • Non-resident Canadian income tax matters
  • Residency matters
  • Permanent establishment matters
  • Transfer pricing adjustments
  • Double taxation of income from real property or business profits
  • Tax withheld 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
  • Regulations 102 and 105 withholding waivers
  • Double taxation on other types of income
  • Foreign tax credit matters

Advance Pricing Arrangements (APA)

Where it is deemed appropriate to obtain, in advance, acceptance of a company’s transfer pricing policies by the fiscal authorities interested by the transactions, DRTP Consulting can assist with the following tasks:

  • 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 studies and database searches
  • Economic expert study and report for advance pricing arrangements (APA) submission

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