![]() Simplified Documentation Requirements for Lower Value Transactions and Smaller Taxpayersĭ.1 Low Value-Adding Intra-Group Servicesĭ.2 Standardized Returns for Distribution ActivitiesĪppendix C – Extracts from Other Jurisdiction's LegislationĪppendix D: Other Administrative Measures ConsideredĪ. Transfer Pricing Documentation and Penalty Provisionsī. Role of OECD Transfer Pricing GuidelinesĮxample 1: Application of "Economically Relevant Characteristics" in Determining the Delineated TransactionĮxample 2: Application of the Hypothetical ComparatorĮxample 3: Application of the Transaction Determination Rule and the Transfer Pricing Application RuleĪ. Non Recognition and Replacement of Controlled Transactionsĭ. Step 2 - The Operation of the ComparisonĬ. ![]() Step 1 - Establishing the Starting Point of the ComparisonĪ.1 Determination of the Transaction or SeriesĪ.2 "Economically Relevant Characteristics"ī. Tax Policy Concerns with the Outcome in CamecoĪ. Recent Canadian Transfer Pricing Case Law – CamecoĬ. Overview of Canadian Transfer Pricing Legislationī. The Current State of Canada's Transfer Pricing Tax LawĪ. Recognition of the Controlled Transaction International Consensus on the Application of the Arm's Length PrincipleĬ. Should you express an intention that your submission, or any portions thereof, be considered confidential, the Department of Finance Canada will make all reasonable efforts to protect this information. Information received throughout this submission process is subject to the Access to Information Act and the Privacy Act. wish any portions of your submission to be kept confidential (if so, clearly identify the confidential portions). ![]() request that your identity and any personal identifiers be removed prior to potential publication and. ![]() consent to the disclosure of your submission in whole or in part.In order to respect privacy and confidentiality, when providing your submission please advise whether you: Submissions should preferably be provided electronically in PDF format or in plain text. Email us your comments and feedback at or send them by mail to : ![]()
0 Comments
Leave a Reply. |
Details
AuthorWrite something about yourself. No need to be fancy, just an overview. ArchivesCategories |