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Marzen Aluminum ruling based on structuring rather than pricing

June 26, 2014

Sophie Harding



The Tax Court of Canada has ruled that, while Marzen Artistic Aluminum provided sales and marketing staff to Starline International (SII) at an arm’s-length price, the documentation presented was insufficient. The ruling is significant because it is the first Canadian decision focusing on the structuring of transactions rather than the pricing.

Marzen contested a transfer pricing adjustment made by the Canada Revenue Agency (CRA) with regards to fees paid by Marzen to SII in 2000 and 2001. SII is a Barbados-based corporation wholly owned by Marzen.

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