Christopher J. Montes, Siobhan A.M. Goguen, "Recharacterization of Transactions Under Section 247: Still an Exceptional Approach", 2018 Conference Report (Canadian Tax Foundation), 21:1-25

Summary Under
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2)

“Accurate delineation” approach in 2017 OECD Guidelines is in fact an economic substance approach (pp. 21:11-12)

The 2017 guidelines allow a...

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Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 9
2017 OECD transfer-pricing guidelines mandate an “accurate-delineation approach” that is contrary to s. 247(2)
  • The approach taken in the 2017 OECD Guidelines of “accurately delineating” a transaction is, in fact, an approach of departing from the...

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