The Resource "Fair Value" is not "Arm's Length": applying and interpreting Subsections 69(1) and 247(2) of the Canadian Income Tax Act

"Fair Value" is not "Arm's Length": applying and interpreting Subsections 69(1) and 247(2) of the Canadian Income Tax Act

Label
"Fair Value" is not "Arm's Length": applying and interpreting Subsections 69(1) and 247(2) of the Canadian Income Tax Act
Title
"Fair Value" is not "Arm's Length": applying and interpreting Subsections 69(1) and 247(2) of the Canadian Income Tax Act
Creator
Subject
Language
eng
Summary
This article examines when a fair market value price is not always the same as an arm's-length price for Canadian transfer pricing compliance purposes. It examines the relationship between the pricing rules in the Canadian Income Tax Act, subsection 247(2), which invokes the arm's length standard, and subsection 69(1), which employs the concept of fair market value in a disposition of property between related parties
Citation source
In: Tax management transfer pricing report. - Washington. - Vol. 15 (2006),
http://library.link/vocab/creatorName
  • Vincent, F
  • Bloom, B. (Brian)
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • arm's length principle
  • fair value
Label
"Fair Value" is not "Arm's Length": applying and interpreting Subsections 69(1) and 247(2) of the Canadian Income Tax Act
Instantiates
Publication
Label
"Fair Value" is not "Arm's Length": applying and interpreting Subsections 69(1) and 247(2) of the Canadian Income Tax Act
Publication

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