The Resource Application of set-offs in transfer pricing disputes : Canada

Application of set-offs in transfer pricing disputes : Canada

Label
Application of set-offs in transfer pricing disputes : Canada
Title
Application of set-offs in transfer pricing disputes : Canada
Creator
Subject
Language
eng
Summary
Part of "Comparative survey : application of set-offs in transfer pricing disputes". The purpose of the survey is to clarify for several countries whether an appeal on the existence of unintentional set-offs may be a successful tool for trying to resolve transfer pricing disputes. It may be, however, that tax authorities are reluctant to accept unintentional or at least undisclosed set-offs in order to avoid that taxpayers develop a strategy of building up undisclosed set-offs that may be of use in cases of transfer pricing disputes. A possible argument for the tax authorities could be that third parties would not allow each other undisclosed and/or unintentional set-offs. This part deals with the relevant factors under Canadian set-offs and transfer pricing law
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 10 (2003),
http://library.link/vocab/creatorName
Boidman, N
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • set-off
  • transfer pricing
Label
Application of set-offs in transfer pricing disputes : Canada
Instantiates
Publication
Label
Application of set-offs in transfer pricing disputes : Canada
Publication

Library Locations

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      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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