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Book S.O. Annual/biannual/biennial
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1250 pages
1 volume bound

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Transfer Pricing in Canada, 2015 Edition
By: François Vincent, LL.L., M.Fisc.
Availability: In Stock

This reference book includes in depth analysis of the regulatory and administrative framework, case law and pending cases, as well as administrative positions

This publication is a single-source reference book that provides a comprehensive review of transfer pricing transactions from a Canadian perspective. Readers will find in depth analysis of regulatory and administrative framework, the case law and pending cases, as well as administrative positions. The book also discusses the important OECD guidelines for determination of an arm's length price for goods and services as well as other topics and issues related to transfer pricing such as penalties, information gathering by the Canada Revenue Agency, competent authority procedure, advance pricing arrangements, valuation for customs purposes and statute-barring provisions. With a thorough analysis and unique insight from an expert in the field of transfer pricing, including illustrative explanations, legislation excerpts and other documents, this book aims to assist tax practitioners to navigate through this complex and sophisticated area of taxation. New in this Edition:
  • Expanded commentary on topics such as transfer pricing court cases, including a detailed analysis and commentary of the Supreme Court of Canada (SCC) decision in the case GlaxoSmithKline: SCC's first decision on transfer pricing case, released on October 18th, 2012
  • Expanded analysis of the power of recharacterization pursuant to paragraph 247(2)(d)
  • New secondary adjustment provisions (subsections 247(12) to 15))
  • Discussion of the new provisions relating to secondary adjustments
  • New sections dealing with the most recent CRA administrative pronouncements (referrals to the Transfer Pricing Review Committee)
About the Author
François Vincent, LL. L., M. Fisc., started his career with the Department of Justice where he was Revenue Canada's principal legal adviser on transfer pricing matters including the implementation of the Advance Pricing Arrangement (APA) programme. François was part of the first Canadian team to handle APAs for Canada. He was also involved in the preparation for litigation of transfer pricing cases. François taught information gathering for transfer pricing purposes and the legal aspects of transfer pricing to the Canada Revenue Agency's auditors and officials.

Since joining the private sector, François' experience and expertise has spanned the gamut of transfer pricing work and industries, with particular emphasis on audit defence and APAs. From planning to documentation and controversy, he has advised multinational enterprises in a multitude of sectors, including automotive, beverage, business management, chemical products, engineering, banking and finance, forestry, pulp and paper, garment, glass, high-tech, household products, mining, movies, pharmaceutical, publishing, software, steel, telecommunications, and toys.

François is the co-author of Canada's transfer pricing guidelines found in Information Circular IC 87-2R and of Canada's original and revised APA guidelines found in Information Circulars IC 94-4 and IC 94-4R. He also drafted Canada's first APA template which remains substantially unchanged. Over the years, François has consistently appeared in the Euromoney Legal Media Group's Guide to the World's Leading Transfer Pricing Advisers and Best of the Best as one of the top transfer pricing advisers in the world.