SeemaSphere
Your gateway to global financial intelligence — featuring key developments in transfer pricing, tax law, and regulatory guidance.
Expore all reads
Public Country-by-Country Reporting Goes Live
For years beginning July 2024 (reports due 2026), Australia will require multinational groups to publicly report key tax and financial data. Transparency standards will rise, with exemptions and penalties clearly defined in draft ATO guidelines.
.jpg&w=3840&q=75)
Stricter Exemptions for CbC Reporting
The ATO is tightening which multinationals can claim exemptions from country-by-country reporting. From 2025, only three narrowly defined exemption categories qualify, and more robust evidence is required from applicants.
.jpg&w=3840&q=75)
Alignment with Latest OECD TP Guidelines
Australia is updating its transfer pricing approach to reflect the 2022 OECD Transfer Pricing Guidelines. These updates concentrate on complex issues such as hard-to-value intangibles and digital business models.
ATO Raises the Bar on Intangibles Review
The ATO will increase scrutiny on transfers (migrations) of intangibles such as software and intellectual property. New guidance and major court decisions from late 2025 will raise documentation and risk assessment standards.
15% Global Minimum Tax Now in Effect
Australia is implementing a 15% global minimum tax (Pillar 2) for large multinational corporations as part of G20 and OECD reforms. These rules take effect from 2024, with further anti-avoidance provisions covering undertaxed profits coming in 2025.
Landmark Alcoa Transfer Pricing Ruling
A recent ruling by the Administrative Review Tribunal in the Alcoa of Australia Ltd v Commissioner of Taxation case clarified the use of Comparable Uncontrolled Price (CUP) data and arm's length standards for both related- and third-party transactions. The decision is final, as it was not appealed by the ATO.
Continued Alignment with OECD Guidelines
Canada applies the arm's length principle to all cross-border transactions, as outlined in sections 247(2)--(4) of the Income Tax Act (ITA). Recent enforcement closely follows the OECD 2022 Transfer Pricing Guidelines for Multinational Enterprises, especially on method choice, comparability, and documentation.
Litigation Trends \& Recent Case Law
Court decisions in 2024–2025 (such as Cameco and Glencore appeals) have clarified acceptable methods, evidence standards, and the CRA's burden of proof. The courts continue to reference the OECD arm's length principle and international best practices in their judgments.
Streamlined Documentation Requirements \& Filing Deadlines
Canadian taxpayers engaging in cross-border dealings with affiliated non-residents must now prepare contemporaneous documentation that strictly follows ITA s.247(4). For fiscal years ending after December 31, 2024, documentation must be completed by the tax return due date (usually within six months after year end). The requirements are enhanced in line with the OECD Master File and Local File standards.
Substantial Penalties for Non-Compliance
If documentation is inadequate or not prepared on time, the CRA may levy a penalty of 10% of any transfer pricing adjustment over the $5,000 threshold. Robust and timely Local and Master Files are key to avoiding penalties and establishing penalty protection.
Showing -89 to -80 of 114 articles
