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December 2007
Transfer Pricing Penalties
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Hejazi, Jamal
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CRA auditors are gaining greater experience and the taxpayer must ensure that its analysis is sufficiently strong that a
CRA auditor cannot challenge it. There are many issues in a transfer pricing study that should be dealt with effectively
to avoid a transfer pricing audit. It is important to adequately compensate a related party so that it earns the profits
it deserves, and that such profit falls within industry norms.
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