Canada proposes deemed dividend tax on transfer pricing adjustments

Canada Budget 2012 proposes secondary adjustment for Transfer Pricing additions; Transfer pricing adjustment increasing Canadian income to be regarded as 'deemed dividend' income of non-resident shareholder in Canadian corporation; WHT

Apr 12, 2012

OECD to simplify transfer pricing rules, develop 'how-to' manual for risk assessment

Essential to simplify TP rules, strengthen guidelines on intangible issues and improve dispute resolution; Need to take into account views of all countries; Global Forum on Transfer Pricing to develop

Mar 28, 2012