Over the past decade or so, Canada has been struggling with the problem of how to effectively deploy their audit verification personnel in the face of increasing complexity in both the applicable domestic tax laws and the transactions and structures used by taxpayers. John Yuan and Chia-yi Chua of McCarthy Tétrault in Toronto explain how the Canada Revenue Agency have begun to employ some form of risk analysis to assist with their internal decision making on what type of taxpayers or issues to pursue.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap