Article

BEPS Cash Box Inconsistent with Canadian Tax Rules

Authors: Nathan Boidman and Michael N. Kandev

Originally published in Canadian Tax Highlights, this article examines the BEPS project’s new transfer-pricing notion of “cash box,” which appears to be inconsistent both with commercial reality and with longstanding Canadian outbound international tax policy.

Download this article.

Key Contacts

Expertise

Related

Federal Budget 2024: How It Impacts You and Your Business

Apr. 16, 2024 - On April 16, 2024 (Budget Day) the Honourable Chrystia Freeland, Deputy Prime Minister of Canada and Minister of Finance, delivered the Liberal Party’s federal budget (Budget 2024). Budget 2024 included a number of proposed changes to the Income Tax Act (ITA) and other tax legislation. ...

Governance Insights: 10 Trends that GCs and Boards Need to Know

Jan. 24, 2024 - The latest edition of Davies’ Governance Insights is now available. In this issue, we explore 10 important trends that will help general counsel and boards navigate the year ahead. In order to help you with your strategic and compliance planning, we discuss issues including the...