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Transfer Pricing

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Osler Update Jul 2, 2024

Dow Chemical and Iris Technologies: Supreme Court rules on jurisdictional issues in tax matters

In this Update: On June 28, 2024, the Supreme Court released its decisions in Dow Chemical and Iris Technologies regarding the respective...

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Dow Chemical and Iris Technologies: Supreme Court rules on jurisdictional issues in tax matters
Osler Update Apr 30, 2024

Transfer Pricing 2024: Law and Practice

The federal government has plans to update the rules that govern transfer pricing — the pricing one branch or division or group of a company...

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Transfer Pricing 2024: Law and Practice
Osler Update Apr 16, 2024

Federal budget briefing 2024

Get expert insight and analysis of the tax proposals in Budget 2024, including the capital gains inclusion rate increase and other new or updated...

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Federal budget briefing 2024
Osler Update Feb 28, 2024

CRA releases revised APA guidance

The CRA revised its guidance on Advance Pricing Arrangements, introducing significant updates to criteria for acceptance into the program. The...

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CRA releases revised APA guidance
Osler Update Feb 23, 2024

OECD releases transfer pricing guidance on a simplified and streamlined approach (Amount B of Pillar One)

The OECD has released its first transfer pricing report on Amount B of Pillar One, which introduces a simplified transfer pricing methodology for...

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OECD releases transfer pricing guidance on a simplified and streamlined approach (Amount B of Pillar One)
Osler Update Dec 11, 2023

Transfer pricing proposals infuse Canada’s tax laws with OECD concepts

Canada’s transfer pricing rules ensure that, for Canadian income tax purposes, the pricing of non-arm’s length cross-border transactions adheres...

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Transfer pricing proposals infuse Canada’s tax laws with OECD concepts
Osler Update Aug 9, 2023

Finance proposes tying transfer-pricing rules to OECD guidelines

An article by Kaitlin Gray discusses Finance’s consultation paper proposing to rewrite Canada’s transfer pricing rules.

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Osler Update Mar 28, 2023

Federal budget briefing 2023

Budget 2023 proposes significant new tax measures, including amendments to the GAAR, and provides additional details for previously announced...

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Osler Update Nov 3, 2022

Fall Economic Statement 2022

The Fall Economic Statement updates previously announced tax measures and proposes new tax measures.

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Fall Economic Statement 2022
Osler Update Aug 10, 2021

TPM-02R: Transfer-Pricing Secondary Adjustments and Repatriation

TPM-02R replaces Transfer Pricing Memorandum TPM-02, “Repatriation of Funds by Non-Residents—Part XIII Assessments,” and certain paragraphs...

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