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)