Sentences with phrase «transfer pricing penalties»

Although the transfer pricing provisions were enacted in 1997, there has only been one case before the courts where transfer pricing penalties were specifically at issue (Marzen Artistic Aluminum Ltd. v Canada, 2016 FCA 34; aff» g. 2014 TCC 194).

Transfer pricing penalties are intended to be a compliance penalty focusing the efforts made by taxpayers to accurately determine arm's length prices or allocations.

We can assist you in guiding you through a process of setting up your transfer pricing methodology, which may be reflected in a benchmarking analysis or a planning transfer pricing analysis, or we can prepare a robust transfer pricing study that would provide transfer pricing penalty protection.

In other words, if an adjustment under subsection 247 (2) exceeds $ 50,000, the taxpayer could be subject to a transfer pricing penalty.

If the application of transfer pricing provisions in the Act results in such an adjustment, a taxpayer may be subject to a transfer pricing penalty, in addition to any tax, interest and administrative penalties due.

The transfer pricing penalty may not apply where a taxpayer made reasonable efforts (i) to determine arm's length transfer prices or arm's length allocations in respect of the transaction, and (ii) to use those prices or allocations for the purposes of the Income Tax Act.

Not exact matches

Does the penalty apply to the «transfer pricing capital adjustment» («TPCA») or the «transfer pricing income adjustment» («TPIA»)?

Marzen demonstrates that even relatively small companies are not safe from transfer pricing audits and penalties.

Penalties will not apply if requirements within subsection 247 (4) are met and reasonable efforts have been made to determine and apply the arm's length transfer price or arm's length allocation.

If Canco did not make reasonable efforts to determine an arm's length transfer price for the purchase in Year X, does a subsection 247 (3) penalty apply to the adjustment in Year X or the adjustment in Year X +7?

exclude applications relating to transfer pricing adjustments or a penalty for incorrect transfer pricing;

Applications relating to transfer pricings adjustments or the penalties levied on large transfer pricing adjustments under subsection 247 (3) of the Canadian Income Tax Act,

Eliminated tax, penalty and interest with respect to proposed taxable liquidation of wholly - owned subsidiary valued in excess of $ 1 billion, elimination of U.S. withholding tax on distributions to foreign parent, determination of tax basis of subsidiary stock under consolidated return regulations, reduction of excess loss account income from termination of group, and elimination of proposed transfer pricing adjustments.