International

Managing Canadian Tax Risk
Addressing what your organization may be facing now and in the future

The global tax environment has seen fundamental changes in recent years. Base erosion and profit-sharing (BEPS), the digital economy, and US tax reform have caused changes around the world and, at the same time, fueled the insatiable appetite of governments for more tax dollars. Canada was not sheltered from this… Read more »

US Tariffs: The EU Perspective
Turning tensions into business opportunities

Following his inauguration on January 20, President Donald Trump signaled his intentions regarding trade policy by stating, “I always say ‘tariffs’ is the most beautiful word to me in the dictionary.”1 The Trump administration promptly took action with executive orders, leading to significant tariff measures between, among others, the United… Read more »

The View From Above
Ten actions Canadian businesses can take to navigate tariff turbulence

Authors’ note. This article was prepared on April 22, updated on July 15, and is accurate as of that date. Please refer to legal counsel for up-to-date information on the status of the trade and tariff measures between Canada and the United States. Since his inauguration in January, US President… Read more »

Transfer Pricing and Valuation in Financial Transactions
The impact of OECD and IRS guidance on credit rating, debt capacity, and interest rates

Business transactions such as mergers, acquisitions, and reorganizations often necessitate the pricing and valuation of financial transactions. Applying different standards may result in different pricing or valuation for the same financial transaction. Therefore, identifying the appropriate valuation standard is crucial. Companies must comply with ever-evolving financial and tax reporting requirements… Read more »

An Overview of the EU Public Country-by-Country Reporting Rules
A comprehensive breakdown, with guidance for preparation

The European Union (EU) has long been at the forefront of furthering corporate transparency and accountability. A significant step in this direction was the introduction of nonpublic country-by-country reporting (CbCR) rules in the EU for fiscal years beginning on or after January 1, 2016.1 The nonpublic CbCR rules require multinational… Read more »

Prepare for Public Country-by-Country Reporting
Getting ahead of risks to reputation

With public country-by-country reporting (CbCR) on the horizon, companies with operations in Europe or Australia may soon have to disclose key information about their tax and business operations by jurisdiction. Companies with operations in Romania may be required to produce public CbCR filings as early as December 31, 2024 (for… Read more »

Meeting Pillar Two Calls for Tax Transformation and Single-Solution Efficiencies
Unified corporation-wide tax solutions permit tax strategizing rather than mere compliance and reactivity

A wait-and-see attitude characterizes this year’s global tax landscape, with the emergence of regulations like BEPS Pillar Two marking a pivotal moment. Designed to address base erosion and profit shifting, BEPS Pillar Two proposes a framework to establish a minimum global corporate tax rate. This initiative signifies a concerted effort… Read more »

Brief Overview of What the Pillar Two Directive Means for Multinational Companies
Pillar Two’s inconsistent adoption by EU member states could complicate an already intricate system of domestic and EU laws that businesses must navigate

Editor’s note: This article was written prior to the OECD’s new administrative guidance on Pillar Two, released June 17. This article examines two central points for multinational enterprises as they grapple with the complexities and novelties of Pillar Two. We first address nuanced interpretations of various points of guidance and… Read more »

Your Complete Pillar Two Playbook
Follow these steps to tackle complexity, allocate resources, automate new processes, and more

Today’s resource-challenged tax departments often find it necessary to focus on what’s most critical. Although the release of the Pillar Two model rules captured attention, its adoption remained uncertain until things abruptly changed at the end of 2022, when three events occurred: The European Union unanimously agreed to a directive… Read more »

VAT in the Digital Age
What's happening now—and what's coming—in the EU

On December 8, the European Commission proposed the VAT in the Digital Age (ViDA) package, arguably the most revolutionary reform concerning the value-added tax (VAT) in the European Union in recent years. The ViDA package includes a proposal to amend the European Union’s Council Directive 2006/112/EC, Regulation 904/2010, and Implementing… Read more »