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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

• Want to comprehend the economic issues related to transfer pricing, such as comparable searches, working capital adjustments and royalty rate determination