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Intra-group loans under the arm’s length principle
Against the backdrop of an increased regulatory focus on funding arrangements, Rachit Agarwal, Joel Cooper and Randall Fox consider some important transfer pricing points for practitioners.
Funding arrangements are an essential consideration..
Online Published Date:
04 September 2019
Appeared in issue:
Vol 24 No 03 - 04 September 2019
Translating tax returns
Tax planning arrangements for online companies with remote customer bases are under scrutiny from various international governments and regulators. Tim Walford-Fitzgerald presents some of the key points up for discussion.
Since the heyday of..
Online Published Date:
04 September 2019
Appeared in issue:
Vol 24 No 03 - 04 September 2019
A review of Canada’s foreign affiliate dumping provisions – prevention of multinational surplus stripping
Mark Woltersdorf and Larry Nevsky consider the detail of the provisions found in Section 212.3 of the Income Tax Act, including their purpose and some application examples.
Online Published Date:
04 September 2019
Appeared in issue:
Vol 24 No 03 - 04 September 2019
Legislation day: Finance Bill 2019/20 is on its way
Draft legislation has been published for consultation ahead of Budget 2019.
In accordance with the Government’s “Tax Policy Cycle” for tax changes, the draft clauses for Finance Bill 2019-20 were published on 11 July 2019. On..
Online Published Date:
04 September 2019
Appeared in issue:
Vol 24 No 03 - 04 September 2019