Canada: Decision in Marzen Aluminum transfer pricing case has released
The Tax Court of Canada has published its judgment in Marzen Artistic Aluminum Ltd. v The Queen (2014 TCC 194) on 10 June 2014 regarding a case of transfer pricing adjustment made by the Canada Revenue Agency (CRA) in respect of fees paid by
See MoreCanada: Filing trust elections for employee benefit, foreign is due 26 June
Employee benefit plan gives benefit to employees who render services to Canadian resident employers, or a stock plan administered through a non-resident trust, require to review if the trust is deemed to be a Canadian resident and under Canada's new
See MoreCanada: Indirect tax challenges for real estate sector
Industry of real estate business may face indirect tax—GST/HST and QST—challenges. The indirect tax rules specific to the real estate industry were further complicated by numerous recent changes—i.e., changes that may significantly increase
See MoreCanada confirming South Korean FTA Terms
The Canadian Government has arranged the final text of its Free Trade Agreement (FTA) with South Korea and upon its entry into force; South Korea will immediately exclude 81.9 % tariff lines duties. Once whole implementation, South Korea will have
See MoreCanadian Tax Freedom Day delayed in 2014
After accounting for all taxes, the research organization said that the average family (with two or more people) will pay CAD43,435 (USD39,763) in taxes in 2014 which is equal to 43.5% of their annual income. The tax burden is going to be heavier if
See MoreCanada: Offering PRPP legislation in British Columbia
In British Columbia, legislation offering Pooled Registered Pension Plans (PRPP) to persons and considered substantively enacted for purposes of IFRS and ASPE as of May 29, 2014. It allows small- and medium-sized business employees and self-employed
See MoreCanada: Mining tax changes in Quebec budget
According to the 2014-15 Quebec budget, Quebec has declared several measures that will impact on the mining industry and it proposes to deduct tax credits and confirms that the mining tax regime would be effective from January 1, 2014. The budget
See MoreCanada: Tax Rules that put pensioners at risk
The pension rules in Canada have failed to cope up with long life expectancies, and impose Registered Retirement Income Fund (RRIF) holders to operate tax-deferred assets down rapidly. Federal tax rules need those with tax-deferred savings to either
See MoreCanada – Tax deduction for SMEs from Quebec 2014-15 budget
The Minister of Finance and the Economy of Quebec has delivered the province’s 2014 budget on June 4, 2014. The budget contains a declaration for a deduction of income tax rate for manufacturing small and medium-size enterprises (SMEs) in Quebec,
See MoreCanada – Newfoundland Budget substantively enacted in 2014
Newfoundland Bill 13 containing tax changes has declared as Newfoundland Budget in the 2014. As Newfoundland has a majority government, the bill is allowed substantively enacted for motives of IFRS and ASPE as of May 26, 2014. Bill 13 contains
See MoreCanada: Searching for Block Expanded Expat Voting Rights
The Government desires to appeal a recent court judgment stating that expats who have been outside the country for more than five years should be approved to vote and it was said by Canada's Minister for Democratic Reform. The shortcomings were
See MoreCanada: New guidance regarding contemporaneous documentation
The CRA’s updated Transfer Pricing Memorandum (TPM-05R) clarifies the CRA’s process for requesting contemporaneous documentation and includes specifically four new sections, such as method of delivery, three-month delivery, documents provided to
See MoreCanada -Australia ITT regarding income of employee on a short-term secondment
The Australian Taxation Office has published Interpretative Decision ATO ID 2014/20 on May 30, 2014 regarding the income of a non-resident individual engaged by a resident employer resident in Canada is taxable in Australia despite that the employee
See MoreCanada follows suit with US and excludes references to OECD in TP request
Canada has adopted similar position to the US and has excluded references to the OECD’s three-tier documentation in favour of its own country specific transfer pricing (TP) documentation. The Canada Revenue Agency (CRA) has reviewed its TP
See MoreCanada – Tax proposals in Ontario’s 2014 budget
Ontario’s 2014 budget proposals were announced on 1 May 2014. The measures proposed in the budget include a personal tax increase for individuals earning above CAD150,000; the phasing out of the small business deduction given to some larger
See MoreCanada – Foreign affiliate anti-avoidance rule and tax efficient financing
The Federal Court of Appeal has upheld the verdict of a lower Court that the foreign affiliate anti-avoidance rule does not lead to the loss of the tax deduction in respect of exempt surplus dividends received from a US affiliate using a tax
See MoreTIEA between Bahrain and Canada becomes effective
From April 13, 2014, the Tax Information Exchange Agreement (TIEA) concluded by Bahrain with Canada became effective. These agreements are seen by the international community as an important tool in the effort to curb artificial tax avoidance and
See MoreCanada: TIEA with Bahrain enters into force
On April 3, 2014, the tax information exchange agreement (TIEA) between Canada and Bahrain entered into force. The exchange of tax information is seen as an important element in the fight against tax evasion and enables countries more easily to
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