WebDec 5, 2005 · The purpose of this memorandum is to provide guidelines on how to proceed, in view of the Dudney decision, with cases under audit concerning fixed base or permanent establishment (PE) determinations under Canadian income tax conventions (also referred to as treaties ), to provide a framework for general PE determinations, to raise some other … WebJun 21, 2024 · On June 21, 2024, the Canada Revenue Agency (CRA) replaced its Transfer pricing memorandum (TPM) on downward transfer pricing adjustments, …
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WebCanada updates guidance on role of multiple year data in transfer pricing analyses February 19, 2015 The Canada Revenue Agency (CRA) has issued its 16th Transfer Pricing Memorandum (TPM), Role of Multiple Year Data in Transfer Pricing Analyses, which was posted on its website February 13, 2015. WebJun 30, 2016 · The Canada Revenue Agency (CRA) has issued its 15th Transfer Pricing Memorandum (TPM), Intra-group services and … building in 100 year floodway
15 September 2024 IFA Roundtable Q. 5, 2024-0853401C6 - Tax …
WebDec 6, 2024 · For more information on the treatment of payments or fees made after importation, refer to Memorandum D13-4-3, Customs Valuation: Price Paid or Payable, and Memorandum D13-4-13, Post-importation Payments or Fees (Subsequent Proceeds). Additional information. 28.For more information on transfer pricing for income tax … WebAug 10, 2024 · On June 1, 2024, the CRA updated its guidance on this subject by issuing Transfer Pricing Memorandum TPM-02R, “Secondary Transfer Pricing Adjustments, Repatriation and Part XIII Tax Assessments ... WebThe Canada Revenue Agency (CRA) has issued its 15th Transfer Pricing Memorandum (TPM), Intra-group services and section 247 of the Income Tax Act, which was posted on … building in 100 year floodplain