The GE Capital case shone a spotlight on whether and how “implicit support” should be allowed for in the analysis of intra-group debt. This article explores implicit support in greater detail and begins to outline a transfer pricing framework for dealing with this issue.
CRA strengthens its Transfer Pricing Practice
“We are excited to welcome Arin to CRA,” said Paul Maleh, President and Chief Executive Officer of Charles River Associates. “He has more than three decades of...