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Media Coverage

Mining Weekly quotes Jenny Mboutsiadis and Christopher Steeves on the CRA’s involvement of multinational enterprise use of transfer prices

Fasken
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“Multinationals to heed taxman’s further-reaching hand as transfer pricing disputes come to a head” by Henry Lazenby, Mining Weekly.

Mining Weekly quotes Toronto lawyers Jenny Mboutsiadis and Christopher Steeves in an article on the CRA’s involvement of multinational enterprise use of transfer prices.

According to Fasken Martineau partner in the tax practice group Jenny Mboutsiadis, the CRA becomes concerned about transfer prices when multinational enterprises (MNEs) use transfer prices to shift profits from high tax jurisdictions to lower tax jurisdictions.

“The CRA has been sharpening its assessments of transfer pricing in the last six years, resulting in several MNEs [having their earnings] reassessed and [given] penalties,” Mboutsiadis said during a briefing in Toronto on Friday.

Fasken Martineau leader in the tax practice group Christopher Steeves flagged any Canadian corporate structure with a subsidiary in another jurisdiction, any foreign corporate structure with a Canadian component, and multinational corporate structures with corporate lines going in and out of Canada as being likely to be tapped by the CRA for closer scrutiny under transfer pricing rules.

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