Until the decision in the GlaxoSmithKline (Glaxo) case, all previous Canadian court decisions had slavishly applied the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
How do the guidelines now fit into the law and a practical strategy of establishing the correct transfer prices?
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The increasing sophistication of India’s taxation system has led to complexity across tax treaty benefits, permanent establishments, transfer pricing and more, say Sanjay Sanghvi and Ujjval Gangwal of Khaitan & Co
The firm’s final report outlined new mandatory staff training designed to enhance ethical conduct; meanwhile former PwC Australia partner Wayne Plummer has been cleared of wrongdoing