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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.
Our work during 2022 spanned from assisting start-up companies expanding abroad for the first time to advising large multinationals on multibillion-dollar...
In this issue of Insights: Transfer Pricing, we include recent articles on transfer pricing issues, an upcoming speaking engagement, and industry...
CRA is a proud sponsor of the event. Rebel Curd is a panelist during the session titled “Analyzing transfer pricing cases and controversy strategies.” Anna...
Blockchain-based projects can incorporate multiple jurisdictions and require complex governance design, with operational and tax implications. This webinar...
