EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients.
Recent Searches
Trending
-
Advancing Canada’s defence innovation
09 Apr 2026 -
Canadian Insurance Outlook 2026: navigating uncertainty, unlocking opportunity
13 Mar 2026 Financial services -
From bottleneck to accelerator: the strategic role of digital identity controls for industrials and energy companies
18 Feb 2026 Energy and resources
Tax Alert 2026 No. 36, 26 June 2026
In ExxonMobil Canada Resources Company v. The King, 2026 TCC 42, the Tax Court of Canada issued a judgment that significantly expands the transfer pricing jurisprudence in Canada. Madame Justice Lafleur conducted a thoughtful and comprehensive legal analysis of the reassessing provisions found in paragraphs 247(2)(a) and (c) as well as paragraphs 247(2)(b) and (d) of the Income Tax Act.
Publisher’s note: The taxpayer’s expert witnesses referenced in this Tax Alert are Greg Noble and Caton Walker, Ernst & Young LLP partners who provided expert testimony and an Expert Report in the proceedings.
This Tax Alert provides a summary of the decision, including the facts, the issues under review and the rationale for the Court’s decision with respect to the transfer pricing provisions at issue. This Tax Alert also provides commentary on the application of this case to the administration of the transfer pricing laws in Canada, including the impact on taxpayers and practitioners.
Access the full content in the PDF attached below.
Read Tax Alert in full
Issue No. 36, 26 June 2026
Stay ahead of fast-moving policy developments.
Learn what’s happening now, what it means for your business and how you can adapt to shape the future with confidence. Sign up for EY Tax Alerts today.
Previous issues
Federal spring economic update tax bill now enacted
On 18 June 2026, amended federal Bill C-30, Spring Economic Update 2026 Implementation Act (Bill C-30), received Royal Assent.
On 12 June 2026, the Canada Revenue Agency (CRA) announced that it is further extending the administrative relief from Regulation 105 withholding tax on subcontractor fees reimbursed to non-residents that it previously granted, from 30 June 2026 to 31 March 2027.
Alberta revises industrial carbon prices
On 15 May 2026, the federal government released the Implementation Agreement for the Canada-Alberta Memorandum of Understanding of November 27, 2025.
Nunavut Premier and Finance Minister John Main tabled the territory’s 2026 budget on 25 May 2026.
Bill C‑31, Budget 2025 Implementation Act, No. 2, received first reading on 6 May 2026 and contains significant — though mostly previously announced — proposed amendments to Canada’s Global Minimum Tax Act (GMTA) and Income Tax Act.
CRA intends to postpone new administrative position on GST/HST treatment of trailing commissions
On 13 May 2026, the Canada Revenue Agency (CRA) verbally informed various industry groups that it intends to grant a material extension to the implementation deadline for the application of GST/HST to mutual fund trailing commissions.
Publications and articles