On 3 November 2005, the Tax Court of Canada released its judgment in Univar Canada Ltd. v. The Queen 2005 TCC 723. The Court found that Canada's anti-avoidance rules were not violated in circumstances where a Canadian subsidiary of a US parent financed the parent's European operations through the use of a lending subsidiary in Barbados.
Facts
Univar Canada Ltd. (Univar) primarily carried on the business of industrial and agricultural chemical processing and distribution. It was p…