Boidman, Nathan
Evaluating Canada's attempt to reconcile general transfer pricing rules and specific antiabuse provisions / by Nathan Boidman and Michael N. Kandev .-- , 2020
Resumen.
In this article, the authors examine Canadian draft legislation that attempts to reconcile conflicts or overlaps between Canada's general transfer pricing rule, which is based on the arm's-length principle, and various specific statutory anti-base-erosion rules that may also apply to non-arm's-length cross-border situations. They also address apparent defects in the proposal that the government should resolve and look at how similar issues are dealt with in nine other countries, including the United States.
PRECIOS DE TRANSFERENCIA
CANADA
Kandev, Michael
Tax Notes International 1048-3306 v. 98, n. 6, May 11 2020, p. 691-698
Evaluating Canada's attempt to reconcile general transfer pricing rules and specific antiabuse provisions / by Nathan Boidman and Michael N. Kandev .-- , 2020
Resumen.
In this article, the authors examine Canadian draft legislation that attempts to reconcile conflicts or overlaps between Canada's general transfer pricing rule, which is based on the arm's-length principle, and various specific statutory anti-base-erosion rules that may also apply to non-arm's-length cross-border situations. They also address apparent defects in the proposal that the government should resolve and look at how similar issues are dealt with in nine other countries, including the United States.
PRECIOS DE TRANSFERENCIA
CANADA
Kandev, Michael
Tax Notes International 1048-3306 v. 98, n. 6, May 11 2020, p. 691-698