CPA Canada’s Tax blog: CRA Practice Limits Face-to-Face MeetingsPar Robert Robillard - 13 novembre 2014
RBRT Inc. Transfer pricing, tax treaties and other international tax matters
From CPA Canada website:
« In this Tax blog post, Gabe Hayos, Vice President, Taxation, for CPA Canada, discusses why Canada Revenue Agency’s appeals officers don’t accept face-to-face meetings to resolve disputes more often.[…]
The Appeals Branch has indicated that appeals officers would agree to meet face-to-face if:
- a file is complex or the appeal is based on a provision that permits a range of technically correct applications
- the appeals officer is responding to a complaint on the conduct of CRA officials on the file
- the file is headed to tax court and the practitioner insists on a meeting
- the appeals officer believes that the credibility of the taxpayer is an issue and wants to assess that credibility in person […] »
See the full blog post here.
RBRT Inc. is all about transfer pricing. We specialize in transfer pricing, tax treaties and other international tax matters. Our services include transfer pricing documentation (transfer pricing policies and procedures, BEPS and C-doc), transfer pricing dispute resolution, tax treaty matters including double tax relief, tax treaty-based returns and waivers, advanced pricing agreement (APA), value chain management and TP planning, transfer pricing training. The information in this blog post is general information only. Data and information come from sources believed to be reliable but complete accuracy cannot be guaranteed. RBRT Inc. and the author are not responsible or liable for any error, omission or inaccuracy in such information. Readers should seek independent tax advice and tax counsel from RBRT Inc. as required.