In Print: The Dilemma of GlaxoSmithKline: Unreasonable in the Circumstances?

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The Tax Court of Canada’s (TCC) recent decision in GlaxoSmithKline Inc. provides an opportunity to consider one court’s approach to the application of two documents taxpayers generally rely on when developing transfer-pricing policies: the OECD guidelines and the Canada Revenue Agency’s Information Circular 87-2R. The result also provides a chance to:

• Assess the factors that may influence the outcome of tax litigation
• Compares tax litigation with other forms of resolution, such as advance pricing agreements and competent authority negotiation

The paper’s co-author, PwC transfer pricing partner, Andrew McCrodan examines the basis upon which the TCC reached its decision. Download the PDF below to learn whether he supported the court’s conclusions.