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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.
The Guidance is not prescriptive and leaves solutions to the issues that it raises unanswered. We note that the Guidance is not binding on tax administrations...
In this chapter published in “Transfer Pricing & Dispute Resolution: Aligning strategy and execution,” Sabera Choudhury provides an update on recent...
Sabera Choudhury is a speaker during Session 3: Building Resilient Networks during this 3-part series discussing lessons learned through internal and external...
CRA is a proud sponsor of this event. Robin Hart and Anna Soubbotina are speaking during the webcast and will present all important issues surrounding this...
