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Canadian subsidiary may deduct interest on intercompany loan, court rules

March-16-2016

Lawyer Carrie Smit
Area Tax

Summary

Article originally published in the Multinational Tax & Transfer Pricing News

Excerpt from "Canadian subsidiary may deduct interest on intercompany loan, court rules":

The Canadian Federal Court of Appeal on March 4 delivered its judgment in The TDL Group Co. v. The Queen (2016 FCA 67), holding that a Canadian company is entitled to deduct interest on a loan used to acquire shares of its US subsidiary. In so deciding, the Court overruled the Tax Court of Canada’s 2015 decision in the case.

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