Transfer Pricing Reasonableness Standard Refined by the Federal Court of Appeal in Glaxosmithkline Inc. v. Canada (2010)
August 13th, 2010
In simple terms, when related corporations trade property, services or intangibles across international borders, the outlay is referred to as the transfer price. Pursuant to s. 69(2) of the Federal Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) (“ITA”), the transfer price must be “reasonable in the circumstances” that would exist if the non-resident [...]



