Update on DRTP’s Transfer Pricing Seminars
In partnership with the Canadian German Chamber of Industry and Commerce, DRTP Consulting was in Montreal on March 23, 2016, and in Toronto on April 13, 2016 to discuss recent changes in the international transfer...
Posted by DRTP
On 5 May 2016
Int’l Tax Case Law – Intercompany Fees: No Service Provided
In Edison Transportation, LLC v. The Queen 2016 TCC 80 (available here) heard in the Tax Court of Canada, we learn that : "[1] The Appellant is a corporation incorporated in Florida on December 22,...
Posted by DRTP
On 3 May 2016
OECD: Comments on Latest Discussion Draft (Treaty Entitlement of non-CIV Funds)
The comments are available here : http://www.oecd.org/tax/public-comments-received-discussion-draft-treaty-entitlement-of-non-civ-funds.htm Robert Robillard, Ph.D., CPA, CGA, Adm.A., MBA, M.Sc. Econ., M.A.P. Senior Partner, DRTP Consulting Inc. 514-742-8086; robertrobillard "at" drtp.ca www.drtp.ca The convergence of DRTP Consulting’s tax, accounting and economics expertise...
Posted by DRTP
On 29 April 2016
Canada: Automatic Exchange of Information on Tax Rulings
Numerous BEPS rules are, slowly but surely, being included in tax legislation around the world. From the perspective of tax administrations, exchange of information will be a key of component of the successful implementation of...
Posted by DRTP
On 27 April 2016
OECD: Bermuda to Share BEPS Country-by-Country Reports
The OECD recently indicated that "Bermuda became the 33rd signatory of the Multilateral Competent Authority Agreement for the automatic exchange of Country-by-Country reports (CbC MCAA), which is based on Article 6 of the Multilateral Convention on Mutual...
Posted by DRTP
On 25 April 2016