Canada: New CBSA Transfer Pricing Policy Creates Opportunities And Obligations For Importers

Transfer pricing has been a favorite Canada Border Services Agency (CBSA) enforcement target for some time now. Payments made by importers because of income tax transfer pricing requirements can trigger obligations and liabilities under Canadian customs laws. This arises, for example, when CBSA seeks to assess duties and taxes on upward transfer pricing adjustments and even on the payment of management and administration fees to related parties, claiming that these amounts should be properly […]

By |January 23rd, 2015|

Austria: Constitutional Court Confirms Constitutionality Of Non-Deductibility Of Manager Remuneration Above EUR 500,000

As of 1 March 2014, a restriction on the deductibility of manager remunerations for tax purposes exceeding EUR 500,000 per person and year was introduced in Austria. Any remuneration exceeding that threshold cannot be deducted for tax purposes on the level of the employer company. This restriction was subject to substantive discussions in media and legal literature, with some experts arguing that the provisions may be unconstitutional. The Federal Tax Court (Bundesfinanzgericht) filed a […]

By |January 22nd, 2015|

United States: State Of The 2016 Budget: Preparing For Potential Changes To Tax Law

In last night’s State of the Union address, President Obama referenced his desire to close tax “loopholes” that are commonly used by wealthy individuals and families. Although he did not provide much detail in the speech, his proposed changes to the tax code were released last weekend in a White House “Fact Sheet.” These changes will likely be included in the Administration’s Fiscal Year 2016 budget packet, which will be released on Monday, February 2. […]

By |January 22nd, 2015|