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.
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One of the most common analyses in transfer pricing is on the cusp of being overhauled at a global level. This pending change has the potential to impact many...