When a web-based business with a Barbados structure was assessed by the Canada Revenue Agency, their counsel came to Charles River Associates. We analyzed the reasons for the assessment and the intercompany transactions involved and prepared a transfer pricing study demonstrating that the tax authority had erred in its assessment.
Does your merger trigger Canada’s “rebuttable structural presumption”?
This article, authored by CRA’s Ian Cass, provides a brief reference guide along with a visual tool to help assess whether a merger meets the prescribed market...