TPM-09 Reasonable efforts under section 247 of the Income Tax Act Archives

Transfer Pricing in Canada: The Transfer Pricing Penalties

By Robert Robillard - 18 January 2019

Transfer Pricing in Canada: The Transfer Pricing Penalties Legislation Since 1997, Canada’s transfer pricing rules have been included in section 247 of the Canadian Income Tax Act (ITA). They are complemented by sections 233.1 ITA, 233.3 ITA, 233.4 ITA, and...

BEPS Transfer Pricing Canada , Business Strategy Transfer Pricing , Transfer Pricing Canada

Transfer Pricing in Canada: Reasonable efforts to Determine an Arm’s Length Price

By Robert Robillard - 17 January 2019

Transfer Pricing in Canada: Reasonable efforts to Determine an Arm’s Length Price Legislation Since 1997, Canada’s transfer pricing rules have been included in section 247 of the Canadian Income Tax Act (ITA). The Canadian transfer pricing rules are managed by...

BEPS Transfer Pricing Canada , BEPS Transfer Pricing Method , Transfer Pricing Canada