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.
Drug pricing rules and tariffs reshape transfer pricing for IP
In the article “Drug Pricing Rules and Tariffs Reshape Transfer Pricing for IP,” published in Bloomberg Tax, CRA’s Transfer Pricing experts Robin Hart and ...