Abstract
This article contrasts a recent transfer pricing decision of the Tax Court of Canada with the principles set out in the OECD’s Base Erosion and Profit Shifting (BEPS) Actions 8-10. The court decision confirmed the importance of selecting controlled transactions for review with care and precision, emphasized the contractual relationships between associated entities when determining the correct allocation of risk and affirmed the primacy of traditional transfer pricing methods, particularly the CUP method, over the transactional profit methods.
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