Jean Marc Gagnon and Emmanuel Sala, of Blake, Cassels & Graydon, examine how the Tax Court of Canada’s decision to let the Canada Revenue Agency (CRA) introduce new transactions as evidence on the eve of a transfer pricing trial extends the CRA’s right to advance alternative arguments supporting an assessment.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos
The big four firm reportedly sent ‘threatening’ correspondence to Unity Advisory over its hiring of ex-PwC partners; plus tax recruitment news from the week
Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions