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Canada vs General Electric Capital Canada: JUDGMENT

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Canada vs General Electric Capital Canada: JUDGMENT

Case Information

  • Court: Federal Court of Appeal
  • Case No: A-1-10
  • Applicant: Her Majesty the Queen
  • Defendant: General Electric Capital Canada Inc. (GE Canada)
  • Judgment Date: 15 December 2010

The case of Canada v. General Electric Capital Canada Inc. (2010 FCA 344) revolved around whether guarantee fees paid by GE Canada to its parent company, GECUS, adhered to the arm’s length principle under Canadian tax law. GE Canada claimed deductions for these fees in its income calculations for the 1996–2000 taxation years. The Minister of National Revenue reassessed these deductions, arguing that the fees exceeded arm’s length amounts and provided no tangible benefit to GE Canada, and thus were superfluous.

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Categories: Canada
Tags: ALP, Arms Length Principle, Credit Swap Method, Intra Group Transactions, Tax Risk Management, Transfer Pricing, Yield Approach
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5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected