Transfer pricing alert archive |
Transfer pricing alert is published as issues develop.
2012
October 19, 2012: Supreme Court of Canada hands down partial victory for GlaxoSmithKline, but saga continues
April 26, 2012: Intercompany contingent liability payments: staying well-armed
April 2, 2012: Federal budget 2012: clarity on transfer pricing secondary adjustments and repatriation
January 24, 2012: Supreme Court of Canada hears GlaxoSmithKline case: focuses on business reality concept
2011
December 1, 2011: Action required: year-end competent authority deadlines loom
March 28, 2011: Supreme Court grants leave in GlaxoSmithKline
2010
December 20, 2010: GE Capital Canada – FCA dismisses appeal; implicit support lives
December 16, 2010: Action required: year-end competent authority deadlines loom
December 2, 2010: The uncertainty continues in GE Capital
October 19, 2010: The CRA appeals GlaxoSmithKline decision: arm’s length standard versus business reality
September 13, 2010: Update on GE Capital Canada – different method of pricing a guarantee?
July 30, 2010: GlaxoSmithKline prevails at Federal Court of Appeal; but saga continues
May 14, 2010: Crown clarifies grounds for appeal in GE Capital Canada’s guarantee fee case
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