The Resource Federal Court of Appeal upholds lower Court decision in Marzen : key lessons for Canadian taxpayers

Federal Court of Appeal upholds lower Court decision in Marzen : key lessons for Canadian taxpayers

Label
Federal Court of Appeal upholds lower Court decision in Marzen : key lessons for Canadian taxpayers
Title
Federal Court of Appeal upholds lower Court decision in Marzen : key lessons for Canadian taxpayers
Creator
Subject
Language
eng
Summary
On 29 January 2016, Canada's Federal Court of Appeal (FCA) released its decision in the Marzen Artistic Aluminum case, which concerned the transfer pricing treatment of marketing fees paid to a taxpayer's wholly owned foreign subsidiary. The FCA judgment reinforced certain issues decided by the Tax Court of Canada, including the importance of respecting contracts between separate legal entities and not inappropriately amalgamating separate and distinct entities
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 23 (2016),
http://library.link/vocab/creatorName
  • Dujsic, M
  • Gurr, S
  • Evans, A
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • OECD Transfer Pricing Guidelines
  • transfer pricing
  • taxpayer
  • CUP method
  • case law
Label
Federal Court of Appeal upholds lower Court decision in Marzen : key lessons for Canadian taxpayers
Instantiates
Publication
Label
Federal Court of Appeal upholds lower Court decision in Marzen : key lessons for Canadian taxpayers
Publication

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    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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