Specific international agreements and general trends toward global economic consolidation mean that Canadian business is now more than ever an important part of a highly integrated north American – and increasingly globalized – economy. Nevertheless, unlike the situation in the EU, the Canadian income tax system has undergone little if any change to harmonize its application with the tax systems of its major trading partners.
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Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default