Canada’s recent transfer pricing reforms have opened up the prospect of recharacterization of bundled transactions. Janice McCart of Bennett Jones and Emma Purdy of Ernst & Young in Toronto advise multinationals on how to avoid this worrying possibility
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Pillar two might be top of mind for many multinational companies, but the huge variations between countries’ readiness means getting ahead of the game now, argues Russell Gammon, chief solutions officer at Tax Systems.