Canadian Tax Court Holds that Agreements Reached Under the Mutual Agreement Procedure are Binding on the Canada Revenue Agency
By K. Christy Vouri-Misso and Steven Hannes on May 9, 2017
Posted In Court Procedure Matters, Transfer Pricing Resource, Trial Courts, Uncategorized
On March 10, 2017, the Tax Court of Canada held that agreements reached under the Mutual Agreement Procedure (MAP) precluded the Canada Revenue Agency (CRA) from redetermining the transfer prices of rock salt sold by Sifto Canada Corp. (Sifto Canada) to a related party in the United States. In 2006, Sifto Canada reevaluated the transfer...