International aspects of transfer pricing litigation

Journal
Wilkie, J.S.
International Transfer Pricing Journal 2002 (Volume 9), No. 2
PriceUSD 45

Part of a comparative survey on international aspects of transfer pricing litigation. In this article the basis in the Income Tax Act of the entitlements of the Canada Customs and Revenue Agency to examine foreign-based information in connection with non-arm's-length transactions between Canadian taxpayers and non-residents is considered.