Transfer Pricing and Tax Treaty Case Law in Canada

Transfer Pricing Case Law in Canada

1144020 Ontario Ltd. v. Canada (Minister of National Revenue), 2005 FC 813

AgraCity Ltd v. Canada, 2015 FCA 288

Burlington Resources Finance Company v. The Queen, 2015 TCC 71

Dudney v. The Queen, 1998 TCC 323

Canada v. Dudney, 2000 FCA 14932

European Marine Contractors Ltd. v. Canada (Customs and Revenue Agency), 2004 FC 114

Fidelity Investments Canada Ltd. v. Canada (Canada Revenue Agency), 2006 FC 551

Fundy Settlement v. Canada, 2012 SCC 14

Garron Family Trust v. The Queen, 2009 TCC 450

St. Michael Trust Corp. v. Canada, 2010 FCA 309

General Electric Capital Canada Inc. v. The Queen, 2008 TCC 256

General Electric Capital Canada Inc. v. The Queen, 2009 TCC 246

General Electric Capital Canada Inc. v. The Queen, 2009 TCC 563

Canada v. General Electric Capital Canada Inc., 2010 FCA 92

Canada v. General Electric Capital Canada Inc., 2010 FCA 290

Canada v. General Electric Capital Canada Inc., 2010 FCA 344

HSBC Bank Canada v. The Queen, 2007 TCC 307

Canada (National Revenue) v. JP Morgan Asset Management (Canada) Inc., 2013 FCA 250

Edison Transportation, LLC v. The Queen 2016 TCC 80

Marzen Artistic Aluminum Ltd. v. The Queen, 2014 TCC 194

McKesson Canada Corporation v. The Queen, 2013 TCC 404

Glaxo Smithkline v. The Queen, 2003 TCC 258

GlaxoSmithKline Inc. v. The Queen, 2008 TCC 324

GlaxoSmithKline Inc. v. Canada, 2010 FCA 201

Canada v. GlaxoSmithKline Inc., 2012 SCC 52

Safety Boss Ltd. v. The Queen, 2000 TCC 216

Agence du revenu du Québec c. SAP Canada inc., 2013 QCCQ 4206 

Saipem Luxembourg S.A. v. Canada (Customs and Revenue Agency), 2005 FCA 218

Canada (National Revenue) v. Sifto Canada Corp., 2014 FCA 140

Soft-Moc Inc. v. Canada (National Revenue), 2013 FC 291

Smithkline Beecham Animal Health Inc. v. Canada, 2002 FCA 229

The TDL Group Co. v. The Queen, 2015 TCC 60 (CanLII)

Tax Treaty Case Law in Canada

Black v. The Queen, 2014 TCC 12 (CanLII)

Black v. Canada, 2014 FCA 275 (CanLII)

Tax Treaty Case: Prevost Car Inc. v. The Queen, 2008 TCC 231

Tax Treaty Case: Prevost Car Inc. v. Canada, 2009 FCA 57

Velcro Canada Inc. v. The Queen, 2012 TCC 57

Velcro Canada Inc. v. The Queen, 2012 TCC 273

MIL (Investments) S.A. v. The Queen, 2006 TCC 208

MIL (Investments) S.A. v. The Queen, 2006 TCC 460

Canada v. MIL (Investments) S.A., 2007 FCA 236

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RBRT assists with treaty-based requests, returns and waivers such as non-resident Canadian income tax matters, residency or residence matters, permanent establishment matters, transfer pricing adjustments, double taxation of income from real property or business profits, tax withheld (withholding) on dividends, interests, royalties, management fees, services provided by non-residents, income from real property, issues on income from interest or related to capital gains, double taxation arising on income from employment, pension and annuities, Part XIII Tax withholding under the Canadian Income Tax Act, Regulation 102 and regulation 105 withholding waivers, double taxation on other types of income and Foreign tax credit matters.