The Canada Revenue Agency will be encouraged to increase its use of information gathering powers granted to it under the Canadian Income Tax Act during transfer pricing audits, after the Federal Court allowed its foreign-based information request to examine footwear retailer Soft-Moc’s tax affairs last week.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap