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Taxpayer Wins Major Transfer Pricing Case |
October 23, 2012
Previously published on October 18, 2012
The decision of the Supreme Court of Canada in GlaxoSmithKline was released on October 18, 2012, upholding the decision of the Federal Court of Appeal and referring the matter back to the Tax Court of Canada for redetermination. The issue in the case was the transfer price for ranitidine, the active ingredient in Zantac, an ulcer drug produced by GlaxoSmithKline. The issue in the appeal was what circumstances are to be taken into account in determining the reasonable arm’s length price against which to compare the non-arm’s length transfer price.
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