Comparison of analysis for income tax transfer pricing and customs duties : new information circular

The analytical connection between the valuation of transactions for income tax transfer pricing and for customs duty purposes is a long-standing issue, and the transfer pricing guidelines of the Canadian Revenue Agency in Information Circular IC87-2R make reference to the possible connection. This Information Circular not only is useful with regard to transactional analysis for customs duty purposes, but also can help taxpayers understand the transfer pricing methodologies applied by the CRA in an income tax context.