The Resource The Cameco transfer pricing decision : a victory for the rule of law and the Canadian taxpayer

The Cameco transfer pricing decision : a victory for the rule of law and the Canadian taxpayer

Label
The Cameco transfer pricing decision : a victory for the rule of law and the Canadian taxpayer
Title
The Cameco transfer pricing decision : a victory for the rule of law and the Canadian taxpayer
Creator
Subject
Language
eng
Summary
In this article, the author discusses Cameco, a long-awaited transfer pricing decision from the Tax Court of Canada that criticizes the Canada Revenue Agency's aggressive use of the sham doctrine and its strained interpretation of Canada's transfer pricing rules. The court opts to focus on the parties' actual actions and commercial realities, rather than advance a hypothetical alternative. The ruling is also consistent with Canadian precedent, which takes a notably different approach to transfer pricing than the OECD
Citation source
In: Tax notes international. - Falls Church. - Vol. 92 (2018), no. 9 ; p. 877-902
http://library.link/vocab/creatorName
Suarez, S
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • case law
  • rule of law
  • sham transaction
  • reorganization
Label
The Cameco transfer pricing decision : a victory for the rule of law and the Canadian taxpayer
Instantiates
Publication
Label
The Cameco transfer pricing decision : a victory for the rule of law and the Canadian taxpayer
Publication

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