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.
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While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems
The deal establishes Ryan’s property tax presence in Scotland and expands its ability to serve clients with complex commercial property portfolios across the UK, the firm said