Canada transfer pricing documentation guide
March 10, 2008
Todd Miller and Michael Friedman, of McMillan Binch Mendelsohn, describe the Canadian transfer pricing documentation environment
The Income Tax Act (Canada) contains a special set of statutory rules that operate to impute arm’s length prices to cross-border transactions entered into between Canadian taxpayers and non-residents with which they do not deal at arm’s length. Canadian taxpayers that enter into such transactions must use an appropriate pricing methodology to determine the prices at which the relevant transactions would have been entered into by arm’s length parties.
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