The Queen v. GlaxoSmithKline Inc. – After two decades, still no resolution in Canada Please click on the link for the News on the case, and read below for the Insights. CRA and the OECD The Supreme Court of Canada (SCC) rejected the CRA’s narrow “transaction-by-transaction” approach. What was the CRA thinking? Clearly, the Organisation for … Continue reading
Why is it worth weighing pros and cons of safe harbors*? Because the OECD’s June 6, 2012 draft endorses safe harbors and presents three sample memoranda that countries may use to negotiate bilateral safe harbors. Also, most would say that the IRS has been successful with instituting safe harbors on interest rates for intercompany loans, and … Continue reading
TRANSFER PRICING INSIGHTS 