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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.
One of the most common analyses in transfer pricing is on the cusp of being overhauled at a global level. This pending change has the potential to impact many...
CRA is pleased to be acknowledged in International Tax Review’s (ITR) 2024 World Transfer Pricing Guide as one of the “leading” transfer pricing practices in...
The ITR Managing Tax Disputes Summit will gather in-house tax professionals, tax advisors, and regulators, to provide insight into the key issues and...
Robin Hart is a speaker on “BREAKOUT D: We Just Can’t Get Enough of Pillar 2” and will discuss the progress other countries are making in implementing Pillar...
