On October 5, 2015, the OECD released its package of final reports under the OECD/G20 Base Erosion and Profit-Shifting Project (BEPS). Action 13 of the BEPS Action Plan contains the OECD’s new guidance on a standardized three-tiered approach to transfer pricing documentation and introduces a requirement for large multinational enterprises (MNEs) to provide governments with information on their global allocation of income, economic activity, and taxes paid among countries according to a common template —the Country-by-Country Report (CbC Report). In light of the new CbC Report, CRA has developed a proprietary diagnostic tool that uses CbC data to provide insight into a company’s global transfer pricing position, based on BEPS concepts of value creation and risk alignment. To read more, click the link below.
Significant tax risk to non-US companies created by America First Trade Policy
On his first day in office, President Trump signed two memoranda, the Global Tax Deal and the America First Trade Policy, covering noteworthy international...