In this edition of Insights: Transfer Pricing, we highlight the work of CRA’s Transfer Pricing Practice in 2018, provide a recap of 2018 transfer pricing regulations/guidance and litigation, focus on hot topics such as US tax reform and the digital economy, and look at what lies ahead in 2019.
In a post-BEPS era and with a changing geopolitical environment that resulted in US tax reform and tariffs and trade wars, 2019 will be a significant year in transfer pricing. Issues to be mindful of include the interplay of various tax reform provisions and precedents set by recent court rulings.
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...