Lexis Nexis Transfer Pricing - The Basics from a Canadian Perspective
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Product description
Your Source for Understanding Transfer Pricing in Canada
The increasing globalization of the world's economy has thrust transfer pricing to the top of the list of tax issues that multinational corporations must deal with. Corporations must strike a balance between minimizing taxes and staying onside of transfer pricing rules and regulations set by governments. Avoiding penalties and steering clear of potential audits while trying to maximize profits within lower tax jurisdictions is a complex, but extremely vital exercise.
Dr. Jamal Hejazi brings his vast experience in resolving transfer pricing issues to Transfer Pricing - The Basics from a Canadian Perspective, a new publication from Butterworths that is the perfect solution for anyone dealing with multinational corporation tax issues.
Features and Benefits
Transfer Pricing - The Basics from a Canadian Perspective offers a complete explanation of transfer pricing, analyzes the regulations overseeing transfer pricing and describes how transfer pricing adjustments are raised and resolved within Canada. The reader is provided with:
- Expert commentary - comprehensive coverage of the key components of transfer pricing
- Practical advice - the means to avoid costly penalties by properly composing transfer pricing documentation
- Statute analysis - a complete explanation of Canadian transfer pricing law and regulations from a Canadian and global perspective
- Relevant topics - analysis of contentious transfer pricing issues, including proposed solutions
Understanding Key Multinational Corporation Tax Issues
Transfer Pricing - The Basics from a Canadian Perspective covers all the bases of the most vital tax issues facing multinational corporations, including:
- The various dispute resolution mechanisms available to taxpayers when an international auditor raises an adjustment
- How government can re-characterize a transaction, potentially triggering double taxation
- The most effective methods to ensure that transfer pricing documentation is sound
- How adjustments are raised and resolved in competent authority
An Indispensable Guide
Transfer Pricing - The Basics from a Canadian Perspective is an indispensable guide for in-house counsel, accountants and others concerned in corporate tax matters who:
- Need to understand the rules and regulations associated with transfer pricing in Canada and the lifecycle of a transfer pricing adjustment from initiation to final resolution
- Want to choose the best avenue for dispute resolution relating to a transfer pricing adjustment
Table of contents
Chapter 1: What is Transfer Pricing?
Chapter 2: Arm's Length Principle and Legislative Agenda Regarding Transfer Pricing
Chapter 3: A Closer Look at 243(3): Transfer Pricing Penalties in Canada Subsection 247(3)
Chapter 4: The Power of Governments to Re-characterize
Chapter 5: Documentation and Dispute Resolution
Chapter 6: Recent Developments in Canadian Transfer Pricing
Chapter 7: A Special Look at How Transfer Pricing Works in Canada: The Competent Authority Services Division
Chapter 8: Determination of ALP in a Related Party Setting: Comparable Analysis
Chapter 9: Improving Comparability: Working Capital Adjustments
Chapter 10: Valuation of Intangible Properties
Chapter 11: Royalty Rate Determination
Chapter 12: Intragroup Services
Chapter 13: Guarantee Fees and Intercompany Loans
Chapter 14: Cost Contribution Agreement
Chapter 15: Recent Economic Developments and its Effect on Transfer Pricing: The Case of the BRICs (Brazil, Russia, India and China)
Chapter 16: Consignment Manufacturing
Chapter 17: Permanent Establishments
Chapter 18: Recent Developments in the North American Pharmaceutical Industry
Chapter 19: A Look at U.S. Marketing in the Pharmaceutical Industry: Routine or Atypical
Chapter 20: Customs Valuation for Duty Purposes and Transfer Pricing Methodologies for Tax Purposes
Chapter 21: Should Depreciation be Marked up in a Transactional Net Margin Method Context for Service Providers?
