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International transfer pricing developments: Canada

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. The case also involved a licence agreement between GSK and its parent Glaxo Group for...

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