The Tax Court of Canada has ruled that, while Marzen Artistic Aluminum provided sales and marketing staff to Starline International (SII) at an arm’s-length price, the documentation presented was insufficient. The ruling is significant because it is the first Canadian decision focusing on the structuring of transactions rather than the pricing.
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Two months since EU political agreement on pillar two and few member states have made progress on new national laws, but the arrival of OECD technical guidance should quicken the pace. Ralph Cunningham reports.