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Excavations Marchand et Fils Inc. v. Agence du revenu du Québec, 2025 QCCQ 378 -- summary under Class 29

. The Court cannot consider the control measures and contractual requirements of the client as intrinsic characteristics of a service contract, but must rather considers them as representative of HQ's desire to ensure that its supplier would be able to manufacture in sufficient quantity and supply it with concrete-cement in time and place, taking into account the remoteness of its construction site and the extreme geographical and meteorological conditions of a normal construction site. ...
Decision summary

Resource Capital Fund III LP v. Commissioner of Taxation, [2013] FCA 363 (Fed. Ct. of Austr.), rev'd supra. -- summary under Other

In reaching this conclusion, he found that: the plant and equipment, to the extent it was fixtures, was fixtures to the land (which was not owned by SBM and, therefore, was not TARP of SBM) and not to its mining rights (which were TARP): para. 112 the mining information of SBM (which was not TARP) had a substantial value in light of the substantial exploration cost that would be required to reproduce this information, as well as the substantial present value of the mining production that would be foregone during the three to five year exploration and evaluation process (para. 105, 132) the question of what a hypothetical purchaser would pay for the mining information, being anything in the range of nil (being what it could be sold for by itself) to the full replacement cost (including foregone production as noted above), was indeterminate however, "the fair valuation is one which shares equally between the holder, and the potential user, of the relevant asset the benefit to the user of immediate acquisition of the asset" (para. 157, see also 106, 129), so that the mining information was valued at the mid-point between the two extremes similarly, the plant and equipment should be valued "by dividing the notional ‘bargaining zone' equally" (para. 159, see also 107) between its replacement cost and its minimal scrap value it was not necessary to address whether any value should be assigned to goodwill as the SBM non-TARP assets were more valuable even without doing so it was inappropriate to add an asset value representing the excess of the market capitalization of SBM (which was a listed company) over its discounted cash flow valuation (para. 111, 121) ...
Decision summary

Resource Capital Fund III LP v. Commissioner of Taxation, [2013] FCA 363 (Fed. Ct. of Austr.), rev'd supra. -- summary under Article 13

In reaching this conclusion, he found that: the plant and equipment, to the extent it was fixtures, was fixtures to the land (which was not owned by SBM and, therefore, was not TARP of SBM) and not to its mining rights (which were TARP): para. 112 the mining information of SBM (which was not TARP) had a substantial value in light of the substantial exploration cost that would be required to reproduce this information, as well as the substantial present value of the mining production that would be foregone during the three to five year exploration and evaluation process (para. 105, 132) the question of what a hypothetical purchaser would pay for the mining information, being anything in the range of nil (being what it could be sold for by itself) to the full replacement cost (including foregone production as noted above), was indeterminate however, "the fair valuation is one which shares equally between the holder, and the potential user, of the relevant asset the benefit to the user of immediate acquisition of the asset" (para. 157, see also 106, 129), so that the mining information was valued at the mid-point between the two extremes similarly, the plant and equipment should be valued "by dividing the notional ‘bargaining zone' equally" (para. 159, see also 107) between its replacement cost and its minimal scrap value it was not necessary to address whether any value should be assigned to goodwill as the SBM non-TARP assets were more valuable even without doing so it was inappropriate to add an asset value representing the excess of the market capitalization of SBM (which was a listed company) over its discounted cash flow valuation (para. 111, 121) ...
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…. ...

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