After years of maintaining a reactionary stance, the Canada Revenue Agency (CRA) and the Canadian Department of Justice (DOJ) have collectively refocused their efforts to move earlier and more aggressively, thereby redrawing the battle lines as to the manner in which tax disputes are fought. Brandon Siegal and Chia-yi Chua of McCarthy Tétrault explain how to avoid the cross-hairs of the country’s tax officials.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
ITR spoke to two US TP experts about the long-running dispute, with one arguing that the case highlights ‘weaknesses’ with the comparable uncontrolled transaction method
Authors from Khaitan & Co dissect a ‘welcome’ ruling, which found that the mere existence of a tax benefit would not, by itself, warrant a principal purpose test
Over two-thirds of survey respondents back the continuation of the UK’s digital services tax, research commissioned by the Fair Tax Foundation also found
Cinven’s latest investment follows its acquisition of a stake in Grant Thornton UK in December; in other news, a barrister listed by HMRC as a tax avoidance promoter has alleged harassment
ITR's parent company, LBG, will acquire The Lawyer, a leading news, intelligence and data-driven insight provider for the legal industry, from Centaur Media
KPMG UK’s Graeme Webster and KPMG Meijburg & Co’s Eduard Sporken outline the 20-year evolution of MAPAs, with DEMPE analyses becoming more prevalent and MAPA requirements growing stricter