New Canadian ruling relied on expert evidence
May 25, 2011
Sophie Ashley - TPW
In the Canadian Alberta Printed Circuits (APC) transfer pricing case, the decision relied extensively on the evidence given by expert witnesses on behalf of the taxpayer and the Canadian Revenue Agency (CRA).
The case, which referred to reassessments made by the CRA to the taxpayer’s 1999, 2000 and 2001 tax years, dates back to a time where contemporaneous documentation was in short supply because transfer pricing law had only just been introduced in Canada. As a result the ruling relied, to a large part, on expert witnesses.
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