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Canadian Court Holds Canadian Authority May Not Make Transfer Pricing Adjustment following MAP Resolution with U.S.

|Approved Changes|Canada
Canada

In its decision, dated 10 March 2017, the Tax Court of Canada ruled on whether the Canada Revenue Agency (CRA) may make a transfer pricing adjustment in relation to a transaction that was already adjusted in the U.S. as part of a MAP resolution.

The case involved Sifto Canada Corp. (Sifto), which is engaged in the mining and sale of various salt products, including the sale of rock salt to a…