McKesson Canada presses on with transfer pricing case to Federal Court of Appeal The Tax Court of Canada favoured the Canada Revenue Agency's arguments just before Christmas in a case concerning a receivable sales agreement between the McKesson Canada and its parent company... By Sophie Ashley January 24 2014
McKesson Canada: CRA wins in Tax Court but taxpayer files with Court of Appeal The Canada Revenue Agency (CRA) saw pharmaceutical company McKesson’s arguments dismissed by the Tax Court in December 2013 but the company has now filed its arguments with the Federal Court... By Sophie Ashley January 24 2014
Why the OECD may look at capital receipts but India is unlikely to get its income tax w... India wants the OECD and the UN to consider the issue of capital receipts. The Ministry of Finance would like to see a more international acceptance of the recharacterisation of... By Sophie Ashley January 17 2014
Why a broad brush approach to transfer pricing will not satisfy taxpayers It is increasingly difficult for transfer pricing to be applied generally to industry. Different trades require different approaches and practices from their transfer pricing operations and advisers and governments need... By Sophie Ashley January 14 2014
Vodafone questions applicability of transfer pricing provisions at Bombay High Court Last week’s Vodafone case at the Bombay High Court about the applicability of transfer pricing provisions applied to its transfer of shares with an overseas company was deferred to the... By Sophie Ashley December 05 2013
Vodafone and the applicability of transfer pricing provisions in India Last week’s Vodafone case about the applicability of transfer pricing provisions applied to its transfer of shares with an overseas company was deferred to the Dispute Resolution Panel (DRP) in... By Sophie Ashley December 05 2013
Nicolas Colin discusses French report on digital economy taxation Earlier this year Pierre Collin and Nicolas Colin authored a report, commissioned by the French government, focusing on the taxation of the digital economy. By Sophie Ashley November 27 2013
Armando Lara Yaffar discusses the development of the UN TP manual Armando Lara Yaffar, chairman of the UN tax committee and the deputy director general for international treaties within the department of revenue and public credit at the Ministry of Finance... By Sophie Ashley November 26 2013
An update on Eaton Corporation, Amazon and Altera US transfer pricing trials Next year should see three big transfer pricing litigation cases come to trial in the US: Eaton Corporation, Amazon and Altera. By Sophie Ashley November 19 2013
