Tax Court of Canada releases decision in Sifto transfer pricing case

April 2017

Overview

In early March, the Tax Court of Canada (the TCC) issued its decision in Sifto Canada Corp. and Sifto Canada Corp. (as successor to Sifto Canada Inc.) v. Her Majesty the Queen (Sifto). The TCC sided with the taxpayer, finding that a settlement agreed to via the competent authority process precluded a subsequent reassessment that attempted to further increase the taxpayer’s income. This decision makes clear that settlement agreements reached under Canada’s Mutual Agreement Procedure (MAP) program are generally binding on the CRA.

Contact us

Colm Kelly
Global Leader, Tax and Legal Services
Tel: +353 1 792 8943
Email

Christ Economos
Global Managing Partner, Tax and Legal Services
Tel: +1 (646) 471 0612
Email

Peter Le Huray
Global Tax Service Networks and Markets leader
Email

Erik Bouwman
Global Tax Chief Operating Officer
Tel: +31 (0) 88 792 63 22
Email

Follow us