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Tax authorities lose appeal in GE Capital Canada case

January 05, 2011

Sophie Ashley - TPW

Canada’s Federal Court of Appeal (FCA) has dismissed the Crown’s appeal in the GE Capital Canada (GECC) transfer pricing dispute over the payment of a guarantee fee by a subsidiary to its parent.

While the Crown disagreed with the Tax Court of Canada’s judgment, insisting a new judge was called to hear the case, it did not have any new arguments.

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