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The Bloomberg BNA International Tax Blog is a forum for practitioners and Bloomberg BNA editors to share ideas, raise issues, and network with colleagues. The ideas presented here are those of individuals, and Bloomberg BNA bears no responsibility for the appropriateness or accuracy of the communications between group members.

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Friday, June 3, 2011

Transfer Pricing Rules and Recent Canada Court Action

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In today's issue of BNA Tax Management's Transfer Pricing Report, François Vincent, national leader of KPMG Canada's global transfer pricing services, discusses the result in the Tax Court of Canada's decision in the General Electric Capital case. Even though he agrees with the result, Vincent critiques one aspect arising from it—the notion of implicit support as one of the economically relevant characteristics to be considered in applying the arm's-length principle. 
 
Vincent predicts that coming appeals court action in the case, which is scheduled for November, and the recent decision in GlaxoSmithKline Inc. v. The Queen suggests a solid foundation for the analysis of transfer pricing transactions may be emerging in Canada. 
 
--Rita McWilliams 

 

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