viernes, 18 de marzo de 2016

Canada: The CRA releases guidance on the impact of government assistance on a transfer pricing analysis

On March 2, 2016, the Canada Revenue Agency (CRA) released TPM-17, The Impact on Government Assistance on Transfer Pricing, its latest in a series of transfer pricing memoranda.
TPM-17 provides guidance on the impact and treatment of government assistance in the context of a transfer pricing analysis when using a cost based method to determine transfer prices of goods, services or intangibles sold by a Canadian taxpayer to a non-arm's length non-resident person.
Government assistance is defined as direct and indirect financial assistance received from a government, municipality or other public authority whether as a grant, subsidy, forgivable loan, tax deduction, investment allowance or any other form of assistance. This would include credits for eligible expenses on scientific research and experimental development (SR&ED), interactive digital media (IDM), and film or video production services.
TPM-17 concludes that when a Canadian taxpayer receives government assistance and participates in a cross-border controlled transaction, it is presumed that the Canadian taxpayer will keep the government assistance unless it can be proven that arm’s length enterprises would effectively share all or part of that assistance.
Source & more info: PwC

No hay comentarios:

Publicar un comentario