Scott Wilkie and Janice McCart, of Blake, Cassels & Graydon, explain how multinationals can prepare for risk-based assessments in Canada and abroad by proving the terms of related-party contracts match the substance of their relationships with those entities.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
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