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.
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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties