Charting The Strategic Path Through A Transfer Pricing Dispute

Taxpayers can easily make mistakes navigating a transfer pricing dispute without strategically considering the choices of pursuing domestic avenues for relief or pursuing treaty-based avenues for relief once a transfer pricing reassessment is received.

It is critical for a taxpayer to understand the benefits and risks of each option to strategically navigate the processes.

Domestic avenues for relief generally mean filing a notice of objection with the Canada Revenue Agency (CRA) and either going through the CRA's administrative appeals process and, if unsuccessful, then going to the Tax Court of Canada, or waiting 90 days after filing the notice of objection and going directly to the Tax Court of Canada.