Transfer Pricing Publications

Revisions to the OECD transfer pricing guidelines – Chapters 1-3: Tax Tracks – A PwC Tax Services Podcast Series
In this episode Elisabeth Finch talks about the revisions to the OECD transfer pricing guidelines including why they should pay attention to them, how they might be affected, and how they should respond.

Tax Memo: Guarantee Fees: Federal Court of Appeal Confirms GE Capital Canada Inc. Decision
On December 15, 2010, the FCA dismissed the Crown’s appeal of a 2009 TCC decision that favoured the taxpayer. Get the facts in this Tax Memo.

Tax Memo: Taxpayer Wins Appeal in Transfer Pricing Case (GlaxoSmithKline) – “Business Reality” Prevails
The Federal Court of Appeal set aside the Tax Court’s May 2008 decision regarding the pricing of the active ingredient, ranitidine, in GlaxoSmithKline’s ulcer drug, Zantac. PwC shares the details in this Tax Memo.

Transcript: Tax Tracks – A PwC Tax Services Podcast Series -- Episode 15
Read this transcript to get a better understanding of the transfer pricing audit process. Or visit pwc.com/ca/taxtracks and download episode 15, Pressure Points in the Transfer Pricing Audit Process.

Transcript: Tax Tracks – A PwC Tax Services Podcast Series -- Episode 12
Get our answers to frequently asked questions about advance pricing arrangements (APAs) in this Tax Tracks podcast transcript. Or visit pwc.com/ca/taxtracks and download episode 12, Transfer Pricing APAs.

Transcript: Tax Tracks – A PwC Tax Services Podcast Series -- Episode 11
Read this podcast transcript for guidance on how the GE Capital Canada Inc. case results will impact multinationals. Or visit www.pwc.com/ca/taxtracks to listen to the episode.

Tax Memo: Guarantee Fees: Tax Court of Canada Rules in Favour of GE Capital Canada Inc.
A long-awaited decision between GE Capital Canada Inc. vs. The Queen results in implications for pricing guarantee fees in Canada. PwC shares its observations in this Tax Memo.

In Print: The Dilemma of GlaxoSmithKline: Unreasonable in the Circumstances?
This paper examines how the TCC reached its decision in the GlaxoSmithKline Inc. vs the Queen case.

Insurance Review, Winter 2009
The Winter 2009 edition of Insurance Review provides information on how to enhance the value of actuarial support, examines property tax and reviews recent key accounting, regulatory and tax developments.

Canadian Competent Authority Update
This paper discusses recent activity undertaken by the Canadian Competent Authority to advance the handling of cases through improvements to its advance pricing arrangement program.

Insurance Review, Fall 2008
Insurance Review’s Fall 2008 issue shares developments on the European Union’s new capital management regime and its impact on Canadian insurers. It also discusses transfer pricing issues and IFRS preparation.