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Category Archives: canada
Carbon tax- Decarbonise the old and commercialise the new
The Government is about to announce details of the long awaited carbon tax . It is expected that an emissions trading system (ETS) will be up and running in three to five years. First steps in an effort to get the blighted carbon out of our system and get new energy sources on line (see Labor to impose carbon tax next year, ETS in 2015). At first glance the $23 per tonne price may not derail our economy and wreck … Continue reading
Arm’s length price in transfer pricing – a Canadian view
The case of GlaxoSmithKine Inc. v Canada 2010 FCA 201 (Glaxo II) decided by the Canadian Federal Court of Appeal throws refreshing new light on the factors to be considered when determining what constitutes arm’s length consideration in international agreements. According to the Canadian Federal Income Tax Act the transfer price is that which would have been reasonable in the circumstances if the non-resident person and a taxpayer have been dealing in arm’s length. Similar provision exists in our law … Continue reading
