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No Easy Answers in Canada’s Review of Transfer Pricing Rules

April 23, 2021, 7:57 PM

Canada has no clear answers as it seeks to overhaul transfer pricing rules in the wake of a landmark court defeat at the hands of uranium miner Cameco Corp., tax experts say.

A closer look at rules governing transfer pricing—the process by which multinationals value transactions between their entities as if they were unrelated—was announced in Canada’s April 19 budget proposal following the Supreme Court of Canada’s decision in February to reject an appeal from the Canada Revenue Agency.

“Taking into account the court’s reasoning, the government believes that, without reform, shortcomings in the current transfer pricing rules can encourage ...