Brian Mustard, Sam Maruca, Charles Thériault, Richard Tremblay, "Transfer Pricing: What Are 'Reasonable Efforts,' and When should Penalties Apply?", Canadian Tax Foundation, 2015 Conference Report, 32:1-33 -- summary under Subsection 247(3)
Brian Mustard, Sam Maruca, Charles Thériault, Richard Tremblay, "Transfer Pricing: What Are 'Reasonable Efforts,' and When should Penalties Apply?", Canadian Tax Foundation, 2015 Conference Report, 32:1-33
Unlikelihood of a s. 247(4)(a) safe harbour (p. 32:7)
[T]he qualitative assessment of the adequacy of the actions described in subsection 247(4)...
Words and Phrases