Market leading insight for tax experts
View online issue

International transfer pricing developments: Canada

From Australia to the USA, this is your guide to recent developments around the world

Legislators and judiciaries alike have lent a hand in 2010 to modify aspects of the transfer pricing landscape which is in constant evolution and misunderstood by many multinationals. Confusion around transfer pricing is understandable considering that related parties must assume they are independent of one another when determining intercompany prices thus creating a fictitious event. Recent developments in Canada add some clarity to intangible issues and should lead to shorter completion times for competent authority cases.

Federal Court of Appeal reverses Tax Court of Canada’s Glaxo ruling

In 2008 The Tax Court of Canada (TCC) delivered a controversial decision against GlaxoSmithKline Inc (GSK) upholding a reassessment by the Canada Revenue Agency (CRA) over the price that GSK paid Adechsa a related party for the active ingredient ranitidine found in Zantac....

If you or your firm subscribes to Taxjournal.com, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top