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.
Transfer pricing automation in ERP systems: traps for compliance
In the article “Transfer pricing automation in ERP systems: traps for compliance,” published in International Tax Review, CRA’s Arin Mitra and Robin...