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.
Measuring and mitigating harm from discriminatory taxes
In the article the authors examine the April 2 Executive Order signed by President Trump highlighting US trading partners’ nontariff barriers, such as...