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Transfer pricing alert archive

Transfer pricing alert is published as issues develop.

2014

February 26, 2014: Federal Court of Appeal upholds the Canada Revenue Agency’s request for foreign-based information
February 25, 2014: Customs and transfer prices - Skechers v. CBSA

2013

June 19, 2013: Taxpayer subject to double tax - key takeaways from TeleTech Canada decision

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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