The Resource The Canadian Tax Court again rules in favor of the legal substance of arrangements : observations of the AgraCity case and its impacts

The Canadian Tax Court again rules in favor of the legal substance of arrangements : observations of the AgraCity case and its impacts

Label
The Canadian Tax Court again rules in favor of the legal substance of arrangements : observations of the AgraCity case and its impacts
Title
The Canadian Tax Court again rules in favor of the legal substance of arrangements : observations of the AgraCity case and its impacts
Creator
Subject
Language
eng
Summary
In a recently decided case, the Tax Court of Canada ruled in favour of the Canadian company AgraCity Ltd. and its related company. The author outlines the case as well as its impacts on the concepts of functional analysis, economic substance and accurate delineation of the 2017 OECD TPG
Citation source
In: TPI - Transfer Pricing International. - Wien. - Vol. 4 (2020), no. 6 ; p. 297-304
http://library.link/vocab/creatorName
Screpante, M.S
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • economic substance
  • functional analysis
  • case law
  • sham transaction
  • tax avoidance
  • GAAR
  • transfer pricing
  • OECD Transfer Pricing Guidelines
Label
The Canadian Tax Court again rules in favor of the legal substance of arrangements : observations of the AgraCity case and its impacts
Instantiates
Publication
Label
The Canadian Tax Court again rules in favor of the legal substance of arrangements : observations of the AgraCity case and its impacts
Publication

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