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The Sifto decision is the minister bound by MAP settlements?

Canada - May 16 2017 On March 10, 2017, the Tax Court of Canada (“TCC”) delivered its decision in Sifto Canada Corp. v. The Queen1 regarding the legal effect of a transfer...

Jim Wilson.

IP migration strategies: Pre and post-BEPS

OECD, Canada - June 14 2016 The largest initiative the transfer pricing world has seen, since the introduction of the Organization for Economic Cooperation and Development’s...

Relationship between tax treaties and domestic tax law: scenario involving the Canada-India tax treaty

Canada, India - June 30 2015 A common mistake when analyzing the tax implications of a cross border transaction is to jump too quickly to the ramifications of a tax treaty...

Jim Wilson.

Resolving transfer pricing disputes in Canada

Canada - October 7 2014 The growth in international business has led to more Canadian companies transacting across Borders with related parties, making transfer pricing an...

Pierre G Alary.

China’s move into mining sector: challenges and opportunities from a transfer pricing perspective

China - March 21 2011 China's State Owned enterprises (SOEs) have been expending considerable resources in developing and expanding their outward investments into the natural resource sector....

Dr. Jamal Hejazi, Mark Kirkey, Michael Boehm.