Marzen Artistic Aluminum Ltd. v. The Queen (2014 TCC 194)
I’m don’t know much about this kind of thing, but it doesn’t sound good for Barbados. According to our Google Alerts, the tax sector is abuzz with this latest Canadian ruling that runs 80 pages. (download the ruling here – PDF)
Comments from the cheap seats?
In a lengthy set of reasons, the Tax Court upheld all but a fraction of the CRA’s reassessment of the taxpayer, such reassessments having disallowed the deduction of approximately $7.1M of fees paid by the Canadian taxpayer to its Barbados subsidiary. The Court also upheld the imposition of a penalty under subsection 247(3) of the Act…
… from Dentons Tax Litigation blog: Marzen: Artistic Barbados tax plan defeated