GlaxoSmithKline Inc. - Supreme Court Sends Transfer Pricing Dispute Back to Square One
10/18/2012
Canadian taxpayers who conduct cross-border transactions with related parties have been eagerly awaiting today's decision by the Supreme Court of Canada (SCC) in the transfer pricing case The Queen v. GlaxoSmithKline Inc.
Global Transfer Pricing Review
7/20/2012
KPMG's 2012 Global Transfer Pricing Review, based on a survey by KPMG International's member firms' transfer pricing practices, is designed to help multinational companies stay current with transfer pricing rules worldwide.
Navigating APAs
6/29/2012
With APA activity rising and new programs coming on-stream worldwide, KPMG's survey report Advance Pricing Arrangements: Navigating APAs is a collection of companies' experiences as they engage in Advance Pricing Arrangements.
OECD Proposes "Intangible" Transfer Pricing Guidance
6/12/2012
A working party of the OECD Committee on Fiscal Affairs has released a discussion draft of proposed changes to the OECD's Transfer Pricing Guidelines in the form of a discussion draft on the transfer pricing aspects of intangibles.
Transfer Pricing News - 2011 Report Card on CRA's Mutual Agreement Program
August 9, 2011
The CRA’s 2010-2011 Mutual Agreement Procedure Program Report shows that interest in the program continues to be strong.
Global Transfer Pricing Review - 2011 Edition
April 4, 2011
Globally, transfer pricing is a hot button issue for regulators and companies alike. As globalization widens the reach and ambition of multinationals, CFOs and tax directors face significant new risks in tax regimes with different rules and expanding requirements.
A World in Transition: Managing the Transfer Pricing Implications of Complex Supply Chains
May 31, 2011
Transfer pricing around corporate supply chains has become increasingly complex and closely scrutinized in recent years.
Resolving Canada-U.S. Double Tax Disputes through Arbitration – New Guidance
December 1, 2010
The Canada Revenue Agency (CRA) and Internal Revenue Service (IRS) recently released details on the new procedure to be followed by the Canadian and U.S. competent authorities for cases proceeding to arbitration under the Canada-U.S. tax treaty.
Resolving Canada-U.S. Double Tax Disputes through Arbitration – New Guidance
December 1, 2010
The Canada Revenue Agency (CRA) and Internal Revenue Service (IRS) recently released details on the new procedure to be followed by the Canadian and U.S. competent authorities for cases proceeding to arbitration under the Canada-U.S. tax treaty.
GlaxoSmithKline Inc. — Taxpayer Wins But at What Price?
August 5, 2010
The Federal Court of Appeal (FCA) has reversed the Tax Court of Canada (TCC) decision in GlaxoSmithKline Inc. v. The Queen.
Transfer Pricing News — Completed Advance Pricing Arrangements on the Rise
July 23 2010
The CRA’s 2009-2010 Advance Pricing Arrangement (APA) Program Report shows that interest in the program continues to be strong.
CRA Reports Growing Interest in Advance Pricing Agreements
January 22, 2010
A CRA program report says that the CRA concluded 10 APAs in 2008-09, up from eight completed APAs in 2007-08