Canada

A continuous evolution of transfer pricing

RECORDED WEBCAST  | 

Companies must properly report and document international activity in a rapidly changing global landscape. Tansy Jefferies and Enrique Rayon from RSM’s international tax practice talk about the evolution of transfer pricing and what that means to companies operating globally. 

What impact do recent changes in policies have for transfer pricing approaches of Canadian companies? 

The action plan stemming from the Base Erosion and Profit Shifting (BEPS) global project results in tax authorities focusing on more transparency – but what does that mean? In a nutshell: greater transparency means a new format of documentation. 

Country-by-country reporting is a requirement for Canadian multinational enterprises with consolidated group revenue exceeding €750 million. Secondary reporting mechanisms also exist which require Canadian subsidiaries of multinational enterprises with consolidated group revenue exceeding €750 million to file a country-by-country report under certain circumstances.

The Canadian Revenue Agency has explicitly stated that country-by-country reporting will be used to assess high level transfer pricing risk, BEPS-related risks, and for economic and statistical analysis. We expect this will result in more targeted and in-depth transfer pricing audits, with heightened focus on understanding whether the conduct of the parties aligns with what you're actually documenting in your study. You should expect a greater level of verification of the economic conduct of the parties.

Subscribe to our newsletters

Subscribe


HOW CAN WE HELP YOU?

Contact us by phone +1.855.420.8473 or submit your questions, comments or proposal requests


Events

IN-PERSON EVENT

In-Person Events

We proudly sponsor and participate in events that provide innovative ideas and opportunities for you to improve and grow your business.

IN-PERSON EVENT

Certificate in Not-for-Profit and Charity Finance Leadership

RSM’s Stephen McCourt, national NPO leader, will be providing his insights on ASNPO on January 21, 2019 at CPA Ontario.

  • January 21, 2019

IN-PERSON EVENT

GTA Accountants Network

RSM’s Sunny Jaggi, senior manager, tax, will be speaking at the GTA Accountants Network about changes to income splitting rules.

  • January 22, 2019

IN-PERSON EVENT

OIAA Claims Conference 2019

RSM is proud to sponsor and speak at the Ontario Insurance Adjusters Association’s (OIAA) 2019 Claims Conference this year.

  • January 23, 2019

IN-PERSON EVENT

ACG and Stikeman Elliott Private Equity Mid-Market M&A

On January 31, ACG Toronto and Stikeman Elliott LLP will be hosting a breakfast seminar, RSM's Ben Gibbons will be a panelist.

  • January 31, 2019