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.
OECD issues guidance on transfer pricing implications of COVID-19
The Guidance is not prescriptive and leaves solutions to the issues that it raises unanswered. We note that the Guidance is not binding on tax administrations...