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The document expands considerably upon brief guidance on this topic in CRA's main Information Circular on Transfer Pricing, which dates back to 1999.

The Canadian public company previously known as Silver Wheaton is in the business of providing financing to mining companies in return for a share of their production

A recent Federal Court of Appeal (FCA) case illustrates how contentious transfer pricing disputes can be – even one a taxpayer believed had been resolved!

A recent transfer pricing case from the Tax Court of Canada (McKesson Canada Corporation v The Queen) establishes a broad interpretation of the "regular" (non-recharacterization) transfer pricing rule in the Income Tax Act and offers guidance on the adequacy of contemporaneous documentation. It is therefore an important case for multinationals doing business in Canada.

On June 24, 2015, the World Customs Organization (WCO) published the WCO Guide to Customs Valuation and Transfer Pricing (the Guide).

Osler made a submission [PDF] to the OECD in response to its February 13, 2019 public consultation document on the possible solutions to the tax challenges of digitalization (the 2019 Public Consultation Document).

When the SCC confirmed that discretionary denials under s. 247(10) fall outside the Tax Court's jurisdiction, MEGLobal's appeal was effectively doomed.

Yesterday, the Supreme Court of Canada dismissed the Minister of National Revenue's ("the Minister") application for leave to appeal in the matter of Canada v. Cameco Corporation, 2020 FCA 112.

The Canadian economy, much like the world economy, is completely paralyzed. COVID-19 is the first health emergency that has brought the world economy to a standstill.

Finance released a consultation paper on June6, 2023 proposing to rewrite Canada's transfer-pricing rules. The draft amendments incorporate base erosion and profit shifting (BEPS) concepts...

At the Toronto Centre Canada Revenue Agency & Professionals Breakfast Seminar on February 18, 2014, the CRA provided an update on international and transfer pricing audits.

The OECD recently issued a report targeting corporate tax planning and transfer pricing strategies, which it asserts constitute a serious risk to tax revenues, tax sovereignty among nations and tax fairness.

The Department of Finance released a consultation paper on Canada's transfer pricing rules on June 6, 2023. This consultation was first announced in Budget 2021 following the Supreme Court's...

The Canada Revenue Agency ("CRA") recently canceled Information Circular 87-2R ("IC"), which was a primary policy document on how the CRA applied transfer pricing legislation.

The recent Federal budget outlines several factors influencing M&A and PE. Please see our Budget 2025: Building Canada's Strength article for a more detailed...

The tool is the latest addition to the Canadian version of Blue J Tax and is available for immediate use by subscribers to the platform across the country.

On July 26, 2010, the Federal Court of Appeal issued its decision in the case of GlaxoSmithKline v. R., reversing the Tax Court of Canada's decision and sending the case back to the Tax Court for reconsideration.