Apr 19, 2021
As you may know, we have supported a request to the CRA to extend the April 30 deadline to June 15. But if the deadline is NOT extended, here are some practical tips to reduce the burden of a COVID tax season.
The October 5, 2015 releases from the controversial OECD/G20 BEPS Project are finally here. While there is still work to do on a number of the transfer pricing matters, companies now know what will be considered by tax authorities in modernizing country transfer pricing rules and guidelines.
The outcomes of the BEPS project, on one hand, mean nothing quite yet. The OECD has issued tax policy and guidelines. For these guidelines to be meaningful there must be formal adoption under the law. The G20 members and other BEPS Project participants are committed to proceeding from policy to implementation. An appropriate reaction might follow Ford Prefect’s mantra: “Don’t panic”.
Companies can be fairly certain that the new guidance will be followed reasonably closely by G20 member states and others. It’s therefore good to be prepared like Arthur Dent (who always knows where his towel is) for an eventual meeting with the Vogons of the world’s tax administrations under the amended OECD Transfer Pricing Guidelines. After all, a number of countries have already started enacting BEPS-inspired legislation, and adopting BEPS-like administrative positions. Here is what the future looks like, in brief, and from a high altitude:
In the real Hitchhiker’s, a computer called Deep Thought is designed to calculate the “Answer to the Ultimate Question of Life, The Universe, and Everything”. After 7.5 milion years, the answer that resulted was 42 (it should have been 54). The OECD took 2 years to answer a slightly less difficult question about international tax. Don’t panic.
TRANSFER PRICING NEWSLETTER is provided as a free service to clients and friends of Cadesky Tax. Tax laws are complex and are subject to frequent change. Professional advice should always be sought before implementing a tax planning arrangement or taking an uncertain tax filing position. Cadesky Tax cannot accept any liability for the tax consequences that may result from acting based on the contents hereof.
TAX TIP is provided as a free service to clients and friends of Cadesky Tax.
The material provided in Tax Tip is believed to be accurate and reliable as of the date of posting. Tax laws are complex and are subject to frequent change. Professional advice should always be sought before implementing any tax planning arrangements. Cadesky Tax cannot accept any liability for the tax consequences that may result from acting based on the contents hereof.