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.

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