miércoles, 18 de mayo de 2016

Canada: No cost-based transfer price reduction, government assistance

CRA's longstanding administrative policy is that Canadian taxpayers that take part in non-arm's length cross-border transactions and receive Canadian government assistance should not reduce their cost-based transfer price by the amount of the assistance. This policy is now confirmed in a new Transfer Pricing Memorandum (TPM-17) which the CRA released on March 2, 2016.
The CRA does accept, however, that a Canadian taxpayer may reduce its cost base by the amount of government assistance it has received if there is reliable evidence that arms' length parties would have shared the assistance.

In light of this new guidance from the CRA, taxpayers that deduct government assistance amounts from their costs under a cost-based transfer pricing methodology should be prepared to document support for that reduction on the basis that arm's length parties would have passed some, or all, of the credit on to the foreign recipient of their goods and services.

Source & more info: KPMG

No hay comentarios:

Publicar un comentario