Agences Kyoto ltée v. Agence du revenu du Québec, 2023 QCCQ 2921

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Summaries

Summary Under

a written contract or resolutions were unnecessary for the deductibility of inter-company management fees

The ARQ denied the deduction of the full amount of the management fees paid by the taxpayer (AK) to its wholly-owning parent (GAK) on the basis...

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Summary Under

no requirement for management fees to be pursuant to a written management agreement

The ARQ denied the deduction of the full amount of the management fees paid by the taxpayer (AK) to its wholly-owning parent (GAK) on the basis...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.