Jean Marc Gagnon and Emmanuel Sala, of Blake, Cassels & Graydon, examine how the Tax Court of Canada’s decision to let the Canada Revenue Agency (CRA) introduce new transactions as evidence on the eve of a transfer pricing trial extends the CRA’s right to advance alternative arguments supporting an assessment.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Belt and Road Initiative countries face tax incentive conundrums due to pillar two, but relatively few countries would seek to scrap the project, ITR has heard