Insurance industry. Key tax rates and updates.
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1 Insurance industry Key tax rates and updates Tax changes, rates, deadlines and other useful information for the insurance industry in Canada. 2014
2 Insurance industry: Key tax rates and updates This booklet is available at:
3 Contents Recent tax changes: Selected highlights... 1 Key tax dates... 7 Canadian premium and fire tax Rates and deadlines... 8 Sales tax Rates and deadlines... 9 Corporate income tax rates for Capital tax rates for Publications Insurance help Who to contact For more information, please contact: your PwC insurance industry advisor any of our insurance industry advisors listed at or: Chris Couture National Insurance Leader [email protected] Yves Magnan Corporate Tax Services [email protected] Jason Swales Insurance Leader Tax [email protected] Mario Seyer Indirect Tax Services [email protected] Tax News Network Tax News Network (TNN) provides subscribers with Canadian and international information, insight and analysis to support well-informed tax and business decisions. Try it today at Some cautions Rates and other information are current to August 20, 2014, but may change as a result of legislation or regulations issued after that date. This booklet is published with the understanding that PricewaterhouseCoopers LLP (PwC) is not thereby engaged in rendering accounting, legal or other professional service or advice. Comments in this booklet are not intended to constitute professional advice, nor should they be relied upon to replace professional advice. No part of this booklet may be reproduced without permission from PwC.
4 1 Recent tax changes: Selected highlights Corporate income tax rates for 2014 Combined federal and provincial/territorial corporate income tax rates are listed on page 10. Status of changes for accounting purposes Income tax changes will be recognized for accounting purposes: in Canada if they are considered substantively enacted in the United States if they are enacted Tables on pages 5 to 6 show whether corporate tax rate changes effective after 2012 are recognized for accounting purposes. All information is current to August 20, Federal changes Remittance thresholds for employer source deductions The frequency of employer remittances, which is based on average monthly withholdings from two calendar years ago, will change as follows: Remittances Frequency per month Thresholds for employer source deductions before 2015 after 2014 Up to 2 $15,000 to < $50,000 $25,000 to < $100,000 Up to 4 $50,000 $100,000 Eligible capital property (ECP) regime A public consultation will consider replacing the ECP regime with a new capital cost allowance (CCA) class for businesses and transferring taxpayers existing cumulative eligible capital (CEC) pools to the new CCA class. Draft legislative proposals will be released for comment. The timing of implementation will be determined after the consultation. Life insurers and policyholders Draft legislative proposals, effective upon royal assent, amend the taxation of life insurance policies, generally issued after Key changes amend the determination of: whether a life insurance policy is an exempt policy what types of transactions give rise to a disposition of an interest in a policy the tax treatment of a disposition of an interest in a policy (having regard to both the adjusted cost basis of the interest and the proceeds of disposition) The proposals also include consequential amendments to the life insurer s investment income tax.
5 2 Trusts and estates Taxation Commencing 2016 taxation years, a flat top-rate tax (instead of graduated tax rates) will apply to testamentary trusts, certain estates and grandfathered inter vivos trusts, and these trusts generally will be required to have taxation years ending on December 31 (starting with a deemed taxation year ending on December 31, 2015). Graduated tax rates will continue to apply for testamentary trusts: that arise as a consequence of an individual s death (the first 36 months of the estate only) that have beneficiaries who qualify for the disability tax credit Estate donations Starting with donations made related to a death occurring after 2015, donations made by a will, and those made by designation under a registered retirement saving plan (RRSP), registered retirement income fund, tax-free savings account or life insurance policy, will no longer be deemed to be made by the individual immediately before the individual s death. These donations will be deemed to have been made at the time the property is transferred to a qualified donee and, if the transfer occurs within 36 months after death, they may be allocated among: the taxation year of the estate in which the donation is made an earlier taxation year of the estate the last two taxation years of the individual Foreign Income Verification Statement (Form T1135) Taxpayers required to file Form T1135 must include additional information on foreign property, starting taxation years ending after June 30, Streamlined reporting for certain foreign property will be permitted and the filing deadline for the 2013 taxation year is extended to July 31, See our Tax Insights More changes to Form T1135, Foreign Income Verification Statement at Insurance swaps For taxation years beginning after February 10, 2014, an anti-avoidance rule in the foreign accrual property income (FAPI) regime intended to prevent Canadian taxpayers from shifting income from the insurance of Canadian risks to an offshore captive, is clarified to ensure that it applies to certain tax planning arrangements sometimes referred to as insurance swaps. Thin capitalization rules and back-to-back loan arrangements To target certain back-to-back loan arrangements that have been undertaken by taxpayers using an interposed third party to avoid the application of Part XIII withholding tax and/or the thin capitalization rules: a specific anti-avoidance rule relating to withholding tax on interest payments will be introduced, for amounts paid or credited after 2014 an existing anti-avoidance provision in the thin capitalization rules will be amended, for taxation years that begin after 2014
6 3 Demutualization of property and casualty (P&C) insurers The government confirmed that there will continue to be a consultation on rules in respect of the demutualization of mutual P&C insurers. Treaty shopping Anti-treaty shopping proposal On February 11, 2014, the government proposed a domestic anti-treaty shopping rule that uses a general approach to identify arrangements representing an improper use of Canada s tax treaties, along with guidance regarding its application. Base erosion and profit shifting On July 19, 2013, the Organisation for Economic Co-operation and Development (OECD) released an action plan on base erosion and profit shifting (BEPS). The BEPS initiative contemplates changes to the OECD s model tax convention and recommendations regarding the design of domestic rules to address tax treaty abuse, including treaty shopping. See our: Tax Insights BEPS Where are we? at PKN Alerts OECD reveals highly anticipated action plan on Base Erosion and Profit Shifting (BEPS) and The OECD releases calendar for planned stakeholder input into the BEPS project at Tax planning by multinational enterprises The government is seeking input on issues related to international tax planning by multinational enterprises. Offshore regulated banks For taxation years of taxpayers beginning after 2014, the exception for regulated foreign financial institutions from the FAPI regime will be amended. The aim is to ensure the exception no longer applies to certain Canadian taxpayers that are not financial institutions, but establish foreign affiliates and elect to subject those affiliates to regulation under foreign banking and financial laws, if the affiliate s main purpose is to invest or trade in securities on its own account, rather than to facilitate financial transactions for customers. The rules are far reaching and can impact insurers with foreign affiliates in their structure. Cross-border tax compliance Canada has ratified the Convention on Mutual Administrative Assistance in Tax Matters, which entered into force, in respect of Canada, on March 1, The member States of the Council of Europe and the member countries of the OECD are signatories. Under the convention, Canada will exchange tax information based on OECD standards, but is not required to collect taxes on behalf of another country or provide assistance in the service of related documents. Automatic exchange of information An Intergovernmental Agreement (IGA) between the United States and Canada to improve international tax compliance and to implement the US Foreign Account Tax Compliance Act (FATCA) entered into force on June 27, See our Global IRW Newsbrief Canada and the US sign FATCA Intergovernmental Agreement at
7 4 Tax Information Exchange Agreements (TIEAs) Canada is negotiating eight TIEAs and has signed one that is not in force. Twenty-one have entered into force (one on behalf of five jurisdictions). Automobile deductions and benefits The 2014 prescribed rates will remain at their 2013 levels for purposes of determining automobile deduction limits and taxable benefits. For more information, see Car expenses and benefits A tax guide at Retirement savings plans and deferred profit sharing plans Contribution limits for retirement savings plans and profit sharing plans are increasing: Registered retirement savings plans (RRSPs) Defined contribution registered pension plans (RPPs) Deferred profit sharing plans (DPSPs) 2013 $23,820 $24,270 $12, $24,270 $24,930 $12, $24, Indexed Defined benefit registered pension plans (RPPs) The maximum pension benefit that can be paid from these plans is increasing: Pension benefit (per year of service) 2013 $2, $2, Indexed A special rule that applies in certain limited cases, ensures that the maximum amount that may be transferred tax-free to the RRSP or other registered plans of a departing member of an underfunded defined benefit RPP is the same as if the RPP were fully funded. In certain special circumstances, this special rule is extended to commutation payments made after Goods and Services Tax/ Harmonized Sales Tax (GST/HST) changes for the health care sector For supplies made after February 11, 2014, changes relating to the health care sector, which will reduce the costs to health insurers on policies that cover these services: expand the exemption for training services that assist individuals with a disorder or disability to include the services of designing a training plan expand the list of GST/HST-exempt health care services to include acupuncture, or naturopathic services supplied by a naturopathic doctor, if rendered to an individual zero-rate eyewear specially designed to treat a defect of vision by electronic means if supplied on the written order of a physician or optometrist for use by a consumer named in the order
8 5 Provincial changes British Columbia General corporate income tax rate British Columbia s general corporate income tax rate increased: Effective date Rate Before April 1, % April 1, % Recognized for accounting purposes? Canada US New Brunswick General corporate income tax rate New Brunswick s general corporate income tax rate increased: Effective date Rate Before July 1, % July 1, % Yes Recognized for accounting purposes? Canada US Nova Scotia Harmonized Sales Tax (HST) Nova Scotia will maintain the HST rate at 15% until sustainable fiscal balances are achieved. The rate was to decline to 14% by July 1, 2014, and to 13% by July 1, Ontario General corporate income tax rate This rate is frozen at 11.5% until the province returns to a balanced budget (scheduled for ). The rate was to drop to 11% on July 1, 2012, and to 10% on July 1, Ontario retirement pension plan (ORPP) Employers and employees that do not already participate in a comparable pension plan will each be required to contribute up to about $1,700 annually to the ORPP, starting in See our Tax Insights 2014 Ontario budget: Higher taxes for higher earners and some corporations at Tax avoidance Closing loopholes Ontario: will target schemes and practices that avoid the payment of provincial taxes will implement disclosure rules for aggressive tax avoidance transactions, similar to the federal rules supports federal government initiatives that address aggressive international tax planning urges the federal government to address interprovincial profit and loss shifting Yes
9 6 Enhancing audit Ontario will expand the use of its Flexible and Integrated Risk System program to identify high-risk audit cases Quebec Business tax credits Over 30 business tax credit rates have been reduced by 20%, generally effective on or after June 4, See our Tax Insights June 2014 Quebec budget at Tax holiday for large investment projects For investment projects starting after October 7, 2013, the minimum expenditure threshold for a project to qualify for this 10-year income tax holiday decreased from $300 million to $200 million. Quebec Taxation Review Committee To make the tax system more competitive, the committee will study Quebec s tax system, analyze its tax assistance measures and propose changes before the budget. Saskatchewan General corporate income tax rate Saskatchewan s general corporate income tax rate is decreasing: Effective date Recognized for accounting Rate purposes? Canada US July 1, % Yes To be determined 10% 1 Not as of August 20, Subject to affordability and sustainability within a balanced budget. Alberta, Manitoba, Newfoundland and Labrador, Northwest Territories, Nunavut, Prince Edward Island and Yukon No significant changes were made to the rules that apply to insurers in Alberta, Manitoba, Newfoundland and Labrador, the Northwest Territories, Nunavut, Prince Edward Island or the Yukon.
10 7 Key tax dates The following Canadian tax dates for insurance companies are based on a December 31 fiscal year end. Deadlines falling on holidays or weekends may be extended to the next business day. (Filing dates for miscellaneous matters affecting insurers in Canada, such as provincial taxes, licences, fees, permits and municipal taxes, are not covered.) Federal tax dates Corporate income tax; Financial institutions capital tax Some Canadian-controlled private corporations All other insurers Life insurer s investment income tax Branch tax Non-resident tax T2016 Transactions with NR4 2 non-residents Related-party transactions: T106 T1135 3, T1141 and T1142 Foreign property reporting T1134 Payments Instalments Balance Last day of each month 1 June 30 n/a March 31 February 28 Returns June 30 March 31 June months after year end Federal excise tax unlicensed insurance April 30 Insurers not registered for GST that import taxable supplies 1 month after month of importation Financial institution GST/HST annual information return 4 GST111 Schedule 1 4 n/a June 30 Provincial tax dates Corporate income tax (Alberta; Quebec) Capital tax Payments Instalments Balance Returns Some Alberta Canadiancontrolled private corporations Last day March 31 All other insurers of each month 1 February 28 June 30 Life insurers in Ontario Same as federal corporate income tax Life insurers in Quebec Same as provincial corporate income tax 1. Canadian-controlled private corporations can pay federal and Quebec instalments quarterly (rather than monthly) if certain conditions are met. 2. The payer in a transaction with a non-resident is required to remit withholding tax on or before the 15th of the month following the month the amount was paid or credited to the non-resident. 3. Changes to Form T1135 are discussed on page Financial institutions that have total annual revenues exceeding $1 million and are: GST/HST registrants (but not QST registrants) must file Form GST111 GST/HST and QST registrants must file Form RC7291
11 Canadian premium and fire tax Rates and deadlines Life, accident and sickness 2% 3% Rates 1 Premium tax 4% Property and casualty 3% 4.4% 3% Fire tax 2 Nil Alberta British Columbia % Manitoba 1% New Brunswick Newfoundland Nil 5 and Labrador 3% or 4% 5 N.W.T. & Nunavut 4% 1.25% Nova Scotia Instalments Premium tax If prior year s tax payable exceeds $25,000, 15th of June, September and December Last day of April, July, October and January Last day of June, September and December Deadlines Fire tax 8 Return and balance due 75 days after year end March 31 March 15 Varies 4 March days after end of each quarter March 15 Premium: 60 days after last quarter Fire: March 31 2% 3% or 3.5% 6 Nil Ontario Varies 6 Return: 6 months after year end Balance due: Same as federal income tax (page 7) 3.5% 1% Prince Edward 3 months Last day of each quarter Island after year end 2.3% 3.3% Nil Quebec 7 Same as provincial income tax (page 7) 3% 4% 1% Saskatchewan 8 2% 2% or 3% 9 Nil 9 Yukon Not required March The rates in the table apply to licensed insurers. Different rates may apply to unlicensed insurers in some jurisdictions. 2. Fire tax rates are levied under Fire Prevention Act or similar legislation of each jurisdiction. For Northwest Territories, Nunavut and Yukon, footnotes 5 and 9 set out rates levied under other legislation relating to fire insurance premiums. 3. British Columbia s premium tax rate on property insurance and automobile insurance is 4.4%. A rate of 4% applies to most other types of insurance not referred to in the table. 4. Newfoundland and Labrador s instalment deadlines are shown in the table to the right. Newfoundland and Labrador 5. Northwest Territories and Nunavut impose an additional 1% tax on gross premiums in respect of fire insurance. 6. Ontario levies a premium tax rate of 3.5% on property insurance. Ontario s instalment deadlines are shown in the table to the right. 7. Quebec rates include 0.3% compensation tax on insurance premiums. The compensation tax will be nil after March 31, Saskatchewan imposes an additional 1% tax on gross premiums in respect of motor vehicle insurance. Its premium tax rate on hail insurance is 3%. 9. Yukon imposes an additional 1% tax on gross premiums in respect of fire insurance and property damage insurance. Not required Not required Previous year s tax Instalment deadlines > $1,000,000 20th day of each following month > $500,000 but < $1,000,000 20th of April, July, October and January > $100,000 but < $500,000 20th of July and January < $100,000 Not required Ontario Current or previous year s tax Instalment deadlines > $10,000 a One month after month end b > $2,000 but < $10,000 Three months after quarter end b < $2,000 Not required a. This threshold must be met in both the current and previous year. b. For taxation years that do not end on the last day of a month, instalments are due by the same day of the following month or quarter.
12 9 Sales tax Rates and deadlines Tax Rate Filing conditions Balance and returns Reporting period Due after Default (Registrant) Fiscal year 6 months 2,3 Federal GST 1 5% Fiscal quarter Elected (Registrant) Fiscal month 1 month 2 Alberta No provincial sales tax < $3,000 Fiscal quarter, semi-annual or year Fiscal quarter or Annual > $3,000 to $6,000 British Columbia PST 7% semi-annual 1 month tax Fiscal month or > $6,000 to $12,000 quarter > $12,000 Fiscal month Manitoba PST 8% 4 < $500 Calendar year Monthly $500 to $4,999 Calendar quarter tax > $5,000 Calendar month 20 days New Brunswick Newfoundland and Labrador Northwest Territories HST 13% Same as federal GST No territorial sales tax Nova Scotia HST 15% 5 Same as federal GST Nunavut No territorial sales tax Ontario HST 13% 6 Prince Edward Island HST 14% Same as federal GST Quebec QST 9.975% 7 Same as federal GST 7 Saskatchewan PST 5% < $3,600 Calendar year Annual $3,600 to $7,200 Calendar quarter tax > $7,200 Calendar month 20 days Yukon No territorial sales tax GST = Goods and Services Tax HST = Harmonized Sales Tax PST = Provincial Sales Tax QST = Quebec Sales Tax 1. Instead of the GST, a 5% First Nations Goods and Services Tax (FNGST) applies in certain First Nations. 2. Every registered insurer that is an annual filer and is a: GST/HST (but not a QST) Selected Listed Financial Institution (SLFI), must file Form GST494 GST/HST and QST SLFI (or a QST SLFI but not a GST/HST SLFI), must file Form RC7294 within six months of its fiscal year reporting period. Every registered and non-registered* insurer that is a monthly or quarterly filer and is a: GST/HST (but not a QST) SLFI, must file: (i) interim returns on Form GST494 within one month of its reporting period, and (ii) a final return on Form GST494 within six months of its fiscal year GST/HST and QST SLFI (or a QST SLFI but not a GST/HST SLFI), must file: (i) interim returns on Form RC7200 (registered insurers) or Form RC7262 (non-registered* insurers) within one month of its reporting period, and (ii) a final return on Form RC7294 within six months of its fiscal year Every registered insurer that is not a SLFI must file Form GST34 within either six months of its fiscal year reporting period, or one month of its monthly or quarterly reporting period. Every non-registered* insurer that is not a SLFI must file Form GST62 within one month of its monthly reporting period. * Non-registered insurers must have a monthly reporting period. 3. Federal and Quebec instalments may be due one month after each quarter. 4. Manitoba also applies an 8% retail sales tax (RST) on certain insurance premiums. Manitoba s PST (which also applies to its RST) will decrease to 7% on July 1, Nova Scotia will maintain the HST rate at 15% until sustainable fiscal balances are achieved. The rate was to decline to 14% by July 1, 2014, and to 13% by July 1, Ontario imposes a retail sales tax of 8% on other insurance premiums, with certain exceptions, e.g. individual life and health, and automobile premiums. 7. Quebec s QST reporting has been harmonized with the federal GST reporting. Quebec also imposes a retail sales tax of 5% on automobile premiums and 9% on insurance premiums, with certain exceptions, e.g. individual life and health.
13 10 Corporate income tax rates for 2014 The following rates, which have been pro-rated for a December 31, 2014 year end, apply to insurance companies. For Canadian-controlled private property and casualty insurers, lower rates may apply on up to $500,000 of active business income ($425,000 in Manitoba and $350,000 in Nova Scotia). Basic federal rate 38% Provincial abatement -10% General rate reduction -13% Total federal rate 15% Provincial/ Territorial Provincial/Territorial + 15% federal Alberta 10% 25% British Columbia 11% 1 26% Manitoba 12% 27% New Brunswick 12% 1 27% Newfoundland and Labrador 14% H 29% Northwest Territories 11.5% 26.5% Nova Scotia 16% 31% Nunavut 12% 27% Ontario % % Prince Edward Island 16% 31% Quebec 11.9% H 26.9% Saskatchewan 12% 1 27% Yukon 15% 30% H Tax holidays are available to certain corporations. 1. Recent and future income tax changes are outlined on pages 5 to Ontario corporations that, on an associated basis, have gross revenues of $100 million or more and total assets of $50 million or more, may have a corporate minimum tax (CMT) liability based on adjusted book income. CMT is payable to the extent that it exceeds the regular Ontario income tax liability.
14 11 Capital tax rates for 2014 Federal Alberta Part VI financial institutions capital tax 2 On first $1 billion taxable capital On taxable capital > $1 billion 1.25% Life 1 Non-life 1 Nil British Columbia Manitoba New Brunswick No capital tax Newfoundland and Labrador Northwest Territories Nova Scotia Nunavut On taxable capital < $10 million Nil On taxable capital > $10 million and < $50 million 0.625% Ontario 3 On taxable capital > $50 million and < $100 million % and Quebec 4 On taxable capital > $100 million and < $200 million 1.25% On taxable capital > $200 million and < $300 million 0.625% On taxable capital > $300 million % Prince Edward Island Saskatchewan Yukon 1. All rates in this table are for a December 31, 2014 year end. When applying the thresholds, taxable capital of all companies in a group is considered. 2. The federal Part VI tax is reduced by the corporation s federal income tax liability. Any unused federal income tax liability can be applied to reduce the Part VI tax for the previous three years and the next seven. 3. Ontario capital tax may be reduced by the Ontario income tax and corporate minimum tax payable for the year. 4. Quebec capital tax may be reduced by the Quebec income tax payable for the year.
15 12 Publications PwC issues numerous thought-leadership publications, including those listed below, for Canadian and international insurance and financial services industries. Copies can be obtained from our website at or by contacting any of our Canadian insurance industry advisors, listed at the front of this booklet. Insurance Review: A Canadian perspective This periodic publication discusses the challenges and opportunities facing the insurance industry. It is available at To subscribe, please [email protected]. Insurance Club EyeOpener Webcast and Breakfast Series This series discusses the key trends affecting insurers on a variety of topics. Webcast series are available at To be part of the quarterly breakfast seminars in Toronto, please [email protected]. The insurance industry in 2014 top issues: An annual report This publication describes in detail the challenges insurers face in 2014, and how they can effectively manage their operations and risk, and grow. Topics include: modernizing finance, actuarial and risk management functions, the regulatory environment, reinventing life insurance, the insurance deals market, overcoming common obstacles in policy administration system transformation, and insurance taxation. To download it, visit Insurance Banana Skins 2013: The CSFI survey of the risks facing insurers This survey of the leading members of the insurance industry identifies potential sources of risks to the industry and ranks them by severity. It provides insights into the multitude of risks insurers face globally and focuses attention on addressing risk in an organization. It also questions insurers on current risks, future trends and their preparedness to respond to the risk environment. To download a copy, visit
16 13 Insurance 2020: The digital prize Taking customer connection to a new level This paper discusses how digital innovation can help insurers engage with customers and open up commercial opportunities. It shows how digital is already embedded within the market and holds the key to connecting effectively with customers. For a copy, visit Insurance 2020: Forcing the pace The fast way to becoming a digital front-runner This paper explores how digital is reshaping the competitive landscape for life and pensions businesses, and how to develop the adaptable mindset, and the faster decision-making and operational flexibility needed to come out in front of the market. It is available at Insurance 2020: A quiet revolution The future of insurance M&A This paper makes seven overarching predictions on the global insurance mergers and acquisition market, and recommends how insurance organizations should respond. It explores how mergers and acquisitions are already evolving in life, non-life and specialty insurance markets around the world. To download a copy, visit fs viewpoint Workforce of the future: How strategic workforce planning can help financial institutions today, tomorrow, and beyond This publication addresses the importance of workforce planning and how it can help financial institutions achieve their business goals. Workforce planning helps respond to market changes, adapt to shifting regulatory requirements, and prepare for changes in the workforce. Get a copy at fs viewpoint The art of letting go: Middle- and back-office right-sourcing options for insurance investment management This publication explores outsourcing parts of the insurance investment management function, particularly the middle- and back-office functions, to help insurers remain competitive. For a copy, visit
17 14 fs viewpoint Making a statement: Transforming insurance billing to gain a competitive edge This publication discusses how billing, if deployed strategically, can significantly improve operating efficiency, financial performance and customer satisfaction. Traditionally viewed by insurers as a backoffice function, billing is the most frequent point of contact between insurers and customers. As a result, insurers can use the billing function to strengthen customer relationships, and to differentiate themselves from competitors. This publication is available at fs viewpoint Where have you been all my life? How the financial services industry can unlock the value in Big Data This publication addresses the importance of leveraging the large volumes of enterprise and third-party data to gain insights on customers, their operations, and market opportunities. Sophisticated new data analytical tools are now available for institutions to analyze this data in a timely cost-efficient manner. For a copy, visit 17th Annual Global CEO Survey Leading from the front: Insurance industry summary PwC s 17th Annual Global CEO Survey finds that insurance CEOs view technological advances as the trend most likely to transform their business over the next five years, followed by demographic changes, and then shifts in global economic power. For the key insurance industry findings, download this publication at Canadian Insurance Taxation (Third Edition) The third edition helps insurers identify potential tax problems, make better business decisions and be more effective when discussing these matters with professional advisers. This 454-page book reflects the existing and proposed tax and accounting rules as of November 28, It includes over 80 flowcharts and tables. Changes from previous editions include a new chapter on Canada s transfer pricing environment and insights into transfer pricing methodologies available to insurers. To order this publication, visit
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