For some businesses, there comes a time when an international structure may be called for. This is often the case for Canadian companies selling their products in the world outside of Canada. There are very complex rules in place to deal with such structures.
Non-residents who wish to move to Canada, or simply invest here, are also subject to complex and ever-changing tax rules.
One of the hottest areas of dispute between clients and the tax authorities, in every country, is the issue of Base Erosion and Profit Shifting (BEPS) (aka Transfer Pricing). Most tax jurisdictions have detailed rules to deal with Transfer Pricing issues, and it is important that international clients ensure that their transfer pricing policies comply with the provisions o the Income Tax Act and the policies of the CRA, as well as the guidelines from the OECD and International Chamber of Commerce, and others.
Rotenberg Consulting Inc. has experience and expertise in helping clients structure their businesses and investments while staying within the rules.