Canadian budget clarifies treatment of transfer pricing secondary adjustments and forces multinationals to re-evaluate and better monitor cross-border debt

Canadian budget clarifies treatment of transfer pricing secondary adjustments and forces multinationals to re-evaluate and better monitor cross-border debt

Transfer Pricing

On March 29, 2012, the Minister of Finance proposed significant changes to Canada’s transfer pricing and international tax rules in the federal government’s 2012 budget, including clarifying the treatment of transfer pricing secondary adjustments, changes to thin capitalization rules, and foreign affiliate dumping.

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