Product Details
978-0-7798-6731-8
Book S.O. Annual/biannual/biennial
Annual volumes supplied on standing order subscriptions
1250 pages
1 volume bound
softcover
2018-04-23
Carswell

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Transfer Pricing in Canada, 2018 Edition
By: François Vincent, LL.L., M.Fisc., Michel Ranger, LL.B., BCL.
Availability: In Stock
$150.00
Description

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 the 2018 edition:

  • This edition provides up-to-date case law and enhanced content to reflect recent developments.
  • The entire text has been reviewed and updated.
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.

Michel Ranger is a tax partner in the Montréal office of McMillan LLP, a leading Canadian law firm.  He has over 20 years of experience advising clients on a diverse range of domestic and international taxation matters. 

 Mr. Ranger is recognized for his specialized expertise in structuring domestic and multi-jurisdictional commercial acquisitions, divestitures, reorganizations and business combinations.  Mr. Ranger is highly regarded—both in Canada and internationally—for providing trusted tax advice to foreign businesses investing in Canada, whether through the expansion of their business operations into Canada or the acquisition or financing of existing Canadian businesses.   He regularly works with large Canadian and foreign public and private companies, private equity funds and tax-exempt institutions, which rely on his expertise in international tax issues to direct investments, financings, mergers and acquisitions, and reorganizations.

Mr. Ranger also counsels clients on the tax elements of all major aspects of ongoing business operations, including assisting clients with tax and reporting compliance, transfer pricing, voluntary disclosures and resolving tax disputes with both the Canada Revenue Agency and the provincial revenue authorities.

Mr. Ranger is a frequent speaker on tax matters at a host of leading professional and has authored or co-authored articles and presentations for at a host of leading professional organizations, including the Canadian Tax Foundation (CTF), Wolters Kluwer (CCH), the American Bar Association (ABA), and the Association de planification fiscale et financière (APFF).  Mr. Ranger is a member of the Canadian Tax Foundation, the APFF and the Canadian Bar Association.  He obtained his Bachelor of Civil Law (B.C.L.) and his Bachelor of Common Law (L.L.B.) from McGill University in 1996 and has been a member of the Québec bar since 1997.