The Glaxo decision is a positive one for businesses; however, the Supreme Court of Canada (SCC) has sent a clear signal that the transfer pricing policy established for each related party transaction matters and the transfer prices in the case of multiple transactions, such as the licence of a trademark and the supply of both goods and services, will be carefully scrutinised, argue Claire M.C. Kennedy of Bennett Jones and Brad Rolph, president of Transfer Pricing Specialists.
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The OECD had previously missed a June 30 deadline to agree an MLC on amount A; in other news, UK corporation tax bills surged to a record high last year