Canadian Tax Journal, Volume 43, Issues 5-6Canadian Tax Foundation., 1995 - Taxation |
From inside the book
Results 1-3 of 94
Page 1567
... Pricing : A National Prerogative The recent focusing of attention on transfer pricing is not associated with a single cataclysmic development or event . Rather , interest in the area has gathered momentum over a period of years , as ...
... Pricing : A National Prerogative The recent focusing of attention on transfer pricing is not associated with a single cataclysmic development or event . Rather , interest in the area has gathered momentum over a period of years , as ...
Page 1568
... pricing has clearly moved to the forefront among the many issues confronting gov- ernments and MNES , and the debate is far from over . Transfer Pricing : A New Environment From the adviser's perspective , an entirely new area of ...
... pricing has clearly moved to the forefront among the many issues confronting gov- ernments and MNES , and the debate is far from over . Transfer Pricing : A New Environment From the adviser's perspective , an entirely new area of ...
Page 1593
... pricing agreements.108 Response to OECD Guidelines Canada was quick to respond to the July 1995 release by the OECD of its revised transfer - pricing guidelines . In a news release issued by the De- partment of Finance , 109 the ...
... pricing agreements.108 Response to OECD Guidelines Canada was quick to respond to the July 1995 release by the OECD of its revised transfer - pricing guidelines . In a news release issued by the De- partment of Finance , 109 the ...
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Common terms and phrases
Advance Pricing Agreements amendments amount Appeal apply approach assets basis budget business in Canada Canadian Tax Foundation Canadian Tax Journal canadienne capital cost allowance capital gains carrying on business changes contracting corporation cost countries Cour Court of Canada debt deemed Department of Finance depreciation disposition dividends earned economic entreprise au Canada été être exempt expectation of profit FAPI FCTD federal fiscal foreign affiliate Ibid included Income Tax Act interpretation investment issue l'Association l'impôt legislation limited non-resident OECD model paragraph partner partnership payments percent person provinces provisions Report resident respect result Revenue Canada RRSP rules shareholders shares société statutory subsection supra footnote Supreme Court tax avoidance Tax Conference tax convention tax policy tax rates tax reform tax system tax treaty taxable taxation in Canada taxpayer tion Toronto transactions transfer pricing trust United United Kingdom withholding tax