Transfer Pricing In Canada And The United States

In this day and age, international expansion or simply conducting commercial dealings across borders, without too many hassles, is a taxing proposal. Without a strong understanding of the laws ruling international taxes, peace of mind is, at best, elusive. This book focuses on the rules of transfer pricing within the international tax regime, as they stand in Canada and the United States. Commercial enterprises large and small will benefit from the expert advice in this book. Author Robert Robillard brings his years of experience as an economist, accountant, and teacher to this work. He explains the background of pricing cross-border transactions between related parties, and offers a “Transfer Pricing Tool Kit” for the design, implementation, and documentation of the value chain for business and taxation purposes. Robillard covers the expected and unexpected relationships that will emerge from the cross-border transactions: the transfer pricing audit and the mechanisms available to remedy double taxation, as well as the usefulness of an advisor with respect to the handling of cross-border transactions.

Eden examines how transfer pricing has been handled in different disciplines, including international business, economics, accounting, law and public policy.

In this article, the authors examine Canadian draft legislation that attempts to reconcile conflicts or overlaps between Canada's general transfer pricing rule, which is based on the arm's-length principle, and various specific statutory anti-base-erosion rules that may also apply to non-arm's-length cross-border situations. They also address apparent defects in the proposal that the government should resolve and look at how similar issues are dealt with in nine other countries, including the United States.