There may be a wide range of a reasonable FMVs for management fees respecting a GST/HST self-assessment under ETA s. 272.1(8)

The new rules for investment limited partnerships require the general partner to self-assess based on the fair market value of the periodic management or administrative services that are supplied by it under an agreement for the particular supply of those services to the ILP. If the general partner went to the effort and expense to commission a transfer-pricing type study as to the FMV of its services:

[The] transfer pricing-like study would often generate a range of acceptable arm’s length prices for particular management and administrative services. Would the general partner then be entitled to self-assess any amount of tax within the appropriate range?

See also Henco (“A range of value makes eminent sense. And, where a taxpayer has designated a value that ultimately is found to fall within the range of reasonable fair market value, I see no reason to disturb that figure.”)

Neal Armstrong. Summaries of Alan Kenigsberg, “Changes to Tax Treatment of ILPs under the ETA,” Sales Tax, Customs & Trade, Volume XV, No 2, Federated Press, 2018, p.9 under ETA s. 123(1) - investment limited partnership, s. 217.1(1) and s. 272.1(8).