The Canada Revenue Agency (CRA) has released transfer pricing memorandum 16 (TPM-16), which formalises guidance on multiple year data. While the guidance is far from ground-breaking, the timing of its release appears odd because the OECD’s final recommendations have yet to be published
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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.