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Transfer pricing attracts a lot of attention from tax authorities, generally because large amounts are often involved and most countries are concerned with protecting their own tax base.

In a unanimous decision, the Federal Court of Appeal upheld the Tax Court's decision that Cameco's transactions with its Swiss subsidiary were on arm's length terms and, therefore, compliant with Canada's transfer pricing rules and their underlying policy.

Those who handle individuals’ personal information, including financial details, in the course of business are required to treat that information in accordance with Canada’s privacy laws. This includes getting an individual’s consent as to where and to whom this information is disclosed.

On September 12, 2005, the Canadian International Trade Tribunal (Tribunal) released its statement of reasons continuing, with amendment, an anti-dumping order concerning whole potatoes imported from the United States (U.S.) for use or consumption in British Columbia (B.C.). With the amendment, the Tribunal excluded from its order certain potato types and pack sizes.

Canada has seen numerous transfer pricing developments throughout 2021. Canada's transfer pricing rules are summarized here under 4, Transfer Pricing.

On March 6, 2026, the Tax Court of Canada (the Tax Court) issued a judgment (Judgment) in the matter of ExxonMobil Canada Resources Company v His Majesty the King, 2026 TCC 42 (the Tax Court Appeal)...

As the world economy becomes increasingly globalised, pressure will continue to mount on multinational corporations to maximise overall profits.

MNR v Cameco Corporation, 2019 FCA 67 ("Cameco") was an unsuccessful appeal by the Crown of a failed compliance order application in the Federal Court ("FC").

On June 28, 2024, the Supreme Court released its decisions in Dow Chemical Canada ULC v. The King, 2024 SCC 23 (Dow Chemical) and its companion appeal, Iris Technologies Inc v. A.G. of Canada, 2024 SCC 24 (Iris Technologies).

International tax issues and in particular transfer pricing, is often cited as the number one concern of businesses operating beyond their home border.

Canada provides a participation exemption (exempt surplus) on repatriation of earnings from foreign affiliates.

On May 30th, 2008 the Tax Court of Canada (herein referred to as "Tax Court") ruled on one of Canada's most significant transfer pricing decisions, the case of GlaxoSmithKline Inc.

Canada's Department of Finance has released draft regulations for a new simplified transfer pricing documentation regime under subsection 247(4.1), designed to reduce compliance burdens for eligible taxpayers and partnerships. The regime introduces streamlined requirements for small taxpayers with gross revenue up to C$25-million and certain small transactions, though questions remain about how the simplified analysis differs from existing documentation standards. An anti-avoidance rule ensures the regime c

If a multinational corporation had the luxury of perfect hindsight, it would optimize its global positioning and operational efficiencies by migrating intangible assets prior to those assets proving valuable.

When a Canadian company creates a U.S.-based subsidiary, one of the first issues to be addressed is how to fund those operations.

One area often overlooked during the evaluation and purchase of a target company is tax due diligence.

Canadian businesses and their owners face substantial international tax changes that are overwhelming in their volume and complexity. Significant changes that have been proposed globally and enacted...