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Decision summary
Re Nortel Networks Corp., 2014 ONSC 6973 -- summary under Article 9
Newbould J. rejected the submission made by the administrators of the pension plan for NNUK made (at para. 130) "that the Nortel transfer pricing arrangements failed to compensate NNUK for the true contributions it was making to the Nortel Group …[and] in particular they … failed to properly compensate NNUK for its restructuring costs and its pension costs. ...
Decision summary
Inter-Leasing, Inc. v. Ontario (Revenue), 2014 ONCA 575 -- summary under Subsection 245(4)
For more detail see under s. 115(1)(b) – and respecting the BVI situs issue, see summary under TA, s. 54(2)(b). ...
Decision summary
Veracity Capital Corporation v. M.N.R., 2015 DTC 5136 [at 6421], 2015 BCSC 2278, rev'd 2017 BCCA 3 -- summary under Subsection 245(3)
.): the incorporation of Veracity (which “allowed for the absolute avoidance of B.C. tax, not simply a deferral under s. 85” – para. 42); the transfer of the ALI shares to Veracity (in order to implement the Q-Yes plan; and the adoption of the different year ends. ...
Decision summary
CIT v. Herbalife International India Pvt. Ltd (2016), ITA 7/2007 (Delhi High Court) -- summary under Article 25
. … …[T]he condition under which deductibility is disallowed in respect of payments to non-residents, is plainly different from that when made to a resident. ...
Decision summary
Adobe Systems Inc. v. ADIT, W.P.(C) 2384/2013 (Delhi High Court) -- summary under Article 5
. … There is no evidence that the Assessee has any right to use the premises or any fixed place at its disposal. ...
Decision summary
Gemeente Woerden (Municipality of Woerden) v. Staatsecretaris van Financiën (Secretary of State for Finance, Netherlands), C:2016:466 (European Court of Justice (10th Chamber) ) -- summary under Subsection 141.01(1.1)
. … [I]t follows from the case-law...that if the supply price is lower than the cost price, the deduction cannot be limited in proportion to the difference between the supply price and the cost price, even if the supply price is considerably lower than the cost price, unless it is purely symbolic…. ...
Decision summary
Barlis 06 - Investimentos Imobiliários e Turísticos SA v. Autoridade Tributária e Aduaneira, [2016] EUECJ C-516/14 (European Court of Justice (Fourth Chamber)) -- summary under Subsection 169(4)
…[T]he authorities … must also take account of the additional information provided by the taxable person. ...
Decision summary
Chevron Australia Holdings Pty Ltd v Commissioner of Taxation, [2017] FCAFC 62 -- summary under Retroactivity/Retrospectivity
. … That a person may not be aware at an earlier point in time what the criteria of liability may subsequently be made to apply to that earlier point in time does not make the legislation arbitrary or incontestable…. ...
Decision summary
Google Ireland Ltd. v. France (2017), No. 1505113/1-1 (Tribunal Administratif de Paris) -- summary under Article 5
The Court concluded (at para. 16, TaxInterpretations translation): [I]f SARL Google France had the character of dependent agent within the meaning of (c) of paragraph 9 of Article 2 of the French-Irish Tax Convention, it nonetheless did not exercise, in the years under litigation, the power to bind Google Ireland Limited in commercial relations respecting the transactions constituting the activities of the latter corporation; it follows from this that the Service was incorrect in considering that Google Ireland Limited exercised, through a permanent establishment that was formed by SARL Google France, an activity in France within the meaning of section 182 of the General Income Tax Code …. ...
Decision summary
Lewski v Commissioner of Taxation, [2017] FCAFC 145 -- summary under Subsection 104(24)
It follows that, assuming that each ‘variation of income’ resolution was authorised by the relevant trust deed, the applicant was not “presently entitled” to a share of the net income of the trust estate … for [that] year…. ...