The Glaxo decision is a positive one for businesses; however, the Supreme Court of Canada (SCC) has sent a clear signal that the transfer pricing policy established for each related party transaction matters and the transfer prices in the case of multiple transactions, such as the licence of a trademark and the supply of both goods and services, will be carefully scrutinised, argue Claire M.C. Kennedy of Bennett Jones and Brad Rolph, president of Transfer Pricing Specialists.
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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
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