The Cameco Decision: A Welcome Glimpse of Transfer Pricing in the Post-BEPS World
Mao Ye, A. Gotfried
Abstract
Mao Ye, A. Gotfried
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.
OpenAlex reports 1 citations for this work. Citation counts describe recorded attention and do not establish research quality.
A contribution statement is not available in the OpenAlex record.
Method details are not available in the OpenAlex metadata.
Findings are not separately available in the OpenAlex metadata.
Limitations are not available in the OpenAlex metadata.
Application details are not available in the OpenAlex metadata.
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.
Key concepts: Transfer pricing, Base erosion and profit shifting, Profit (economics), Transactional leadership, Set (abstract data type), Economics, Business, Microeconomics