Canada transfer pricing documentation guide
April 20, 2010
Todd Miller and Michael Friedman of McMillan in Toronto, Canada explain the documentation rules in Canada and how recent treaty developments and court decision will affect taxpayers.
The Income Tax Act (Canada) contains a special set of statutory rules that operate to impute arm’s length prices to transactions entered into between Canadian taxpayers and non-residents with which they do not deal at arm’s length. Canadian taxpayers that enter into such transactions must use an appropriate pricing methodology to determine the prices at which the relevant transactions would have been entered into by arm’s length parties.
Sorry. You must be a subscriber to view this article. Alternatively, why not take a free trial? To subscribe and access this article immediately simply click here or call +44(0)207 779 8380.