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 acknowledged in ITR's 2023 World Transfer Pricing Guide
CRA is pleased to be acknowledged in International Tax Review’s (ITR) 2023 World Transfer Pricing Guide as one of the “leading” transfer pricing practices in...