Traduction de «prêt entre sociétés affiliées » (Français → Anglais) :

transfer prices to affiliates

Movement of Funds Between Canadian Incorporated Insurance Companies and Their Foreign Affiliates, Agencies and Bank Accounts and Other Companies or Persons Outside Canada

Related Party Transactions (Trust and Loan Companies) Regulations [ Regulations prescribing transactions that a company may enter into with a related party of the company ]

Foreign Direct Investment (FDI) typically involves a long-term relationship between the parent and the affiliate and reflects a lasting interest in the host economy.

Broadened outreach and targeted support in particular to grassroots civil society organisations; Supporting businesses and providing loans in local currencies, in partnership with key International Financial Institutions; Improving the capacity of partner countries to take advantage of the trade opportunities with the EU and with each other; Reform commitments and specific investments in the area of energy efficiency; Developing better and safer transport links by 2030 with a long-term investment contributing to connecting the partner countries with the EU and amongst themselves; A digital package, including concrete steps towards h ...[+++]armonised roaming pricing and reduced roaming tariffs among the partner countries, easier and cheaper access to internet through the roll out of national broadband strategies, and support for job creation in digital industries; A substantial new support package to youth and education; A comprehensive new communication approach on assistance for the Eastern Partnership, and a stepping-up of strategic communication.

(1.06) For the purposes of subsections (1.04) and (1.05), if, as part of a series of transactions or events that includes the earning of the foreign accrual property income referred to in subsection (1.03), a foreign affiliate (referred to in this subsection as the “funding affiliate”) of the corporation or of a person (referred to in this subsection as the “related person”) resident in Canada that is related to the corporation, or a partnership (referred to in this subsection as the “funding partnership”) of which such an affiliate is a member, directly or indirectly provided funding to the particular affiliate, or a partnership of whic ...[+++]h the particular affiliate is a member, otherwise than by way of loans or other indebtedness that are subject to terms or conditions made or imposed, in respect of the loans or other indebtedness, that do not differ from those that would be made or imposed between persons dealing at arm’s length or by way of an acquisition of shares of the capital stock of any corporation, then

(4.4) For the purposes of subsections (4.2) and (4.3), if, as part of a series of transactions or events that includes the earning of the foreign accrual property income that gave rise to the particular amount referred to in subsection (4.1), a foreign affiliate (referred to in this subsection as the “funding affiliate”) of the taxpayer or of a person (referred to in this subsection as the “related person”) resident in Canada that is related to the taxpayer, or a partnership (referred to in this subsection as the “funding partnership”) of which such an affiliate is a member, directly or indirectly provided funding to the particular affil ...[+++]iate, or a partnership of which the particular affiliate is a member, otherwise than by way of loans or other indebtedness that are subject to terms or conditions made or imposed, in respect of the loans or other indebtedness, that do not differ from those that would be made or imposed between persons dealing at arm’s length or by way of an acquisition of shares of the capital stock of any corporation, then