Tax & Accounting Blog

Canada Publishes 2017 Report on Advance Pricing Arrangements

Canada Publishes 2017 Report on Advance Pricing Arrangements

On July 12, 2018, the Canada Revenue Agency (CRA) published Advance Pricing Arrangement: Program Report 2017. See BEPS Action 14. The CRA offers the program to assist taxpayers in preventing future transfer pricing (TP) disputes, and to provide increased certainty for transfer pricing methodologies for future intercompany TP transactions (e.g., to establish a … Read More

Reacting to Customs and Border Protection’s (CBP) Ruling Changes

Reacting to Customs and Border Protection’s (CBP) Ruling Changes

Importers today are engaged in complex supply chains where products cross borders multiple times to take advantage of special duty savings programs, free trade agreements, and other manufacturing cost considerations.  It is important to stay on top of the rules for allowing special duty exemptions since there are occasions when CBP will reconsider rulings previously … Read More

India Requests Feedback on Significant Economic Presence

India Requests Feedback on Significant Economic Presence

On July 13, 2018, India’s Central Board of Direct Taxes (CBDT) requested comments and suggestions on “significant economic presence,” which India introduced under section 4 of the Finance Act 2018. See also section 9(1)(i) of the Income Tax Act, 1961 (“ITA”). Double taxation agreements (DTAs) generally provide that a company’s business profits … Read More