What Income Tax Act (R.S.C., 1985, c. 1 (5th Supp.)) - Section 247 requires
This article defines key terms related to transfer pricing, including arm's length principles, qualifying cost contribution arrangements, and various types of tax adjustments, which form the basis for determining tax obligations.
Pillar: Tax & Transfer Pricing · Authority: Government of Canada · Version: 1.0.1 · Last updated:
Primary source: https://laws-lois.justice.gc.ca/eng/acts/I-3.3/section-247.html
SHA-256 integrity: 89c19aab6ced9db108c169d4e1e4e70b26f2109451e0839c727db1de5911e892
Primary Citations — 6 traced to source
- Section 247(1): 'arm's length allocation' means, in respect of a transaction, an allocation of profit or loss that would have occurred between the participants in the transaction if they had been dealing at arm's length with each other.
- Section 247(1): 'arm's length transfer price' means, in respect of a transaction, an amount that would have been a transfer price in respect of the transaction if the participants in the transaction had been dealing at arm's length with each other.
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