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Canadian Transfer Pricing, 2nd Edition

Canadian Transfer Pricing, 2nd Edition

Canadian Transfer Pricing, 2nd Edition

Author: Jules Lewy
Publisher: CCH Canada
ISBN: 9781554964116
Published In: January 2012
Format: Paperback
Jurisdiction: Canada ? Disclaimer:
Countri(es) stated herein are used as reference only

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Canadian Transfer Pricing describes and clarifies Canada's current transfer pricing rules. It sets out the methods used by the CRA and described in the OECD Guidelines for determination of an arm's length price for goods and services.

Due to the large dollar amounts involved in transfer pricing disputes, the importance of transfer pricing to the Canada Revenue Agency ("CRA") continues to evolve into a prominent component of tax collection and enforcement in Canada. Tax practitioners and company executives need to be aware of the procedures and documentation requirements in order to remain compliant with the transfer pricing rules and to be better prepared in the face of an audit by the CRA. This is also true for companies intending to establish an APA or resolve disputes with the revenue authorities inCanada and overseas with respect to transfer pricing transactions.

Authored by Jules Lewy, BCL, LLB and members of the tax group of one of Canada’s largest and most respected law firms, Dentons, Canadian Transfer Pricing provides a comprehensive overview of the Canadian transfer pricing regime. This essential edition includes discussion on the OECD’s involvement in the area of transfer pricing tax policy as well as a brief overview of the U.S. transfer pricing legislation.
1. What is Transfer Pricing?
2. Transfer Pricing Rules Prior to 1999
3. Canada’s Current Transfer Pricing Rules
4. Transfer Pricing and Intra Group Services
5. Transfer Pricing and Restructuring
6. Contemporaneous Documentation and Transfer Pricing Penalties
7. Advance Pricing Agreements
8. Transfer Pricing Audit Process
9. Transfer Pricing Dispute Resolution
10. Competent Authority
11. Jurisprudence
12. Transfer Pricing and Customs, GST and HST.

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