Addresses IP issues and the transfer pricing concerns of Canadian tax authorities. Also includes an analysis of a recent transfer pricing court case. With little Canadian jurisprudence of transfer pricing of IP, this case identifies several transfer pricing considerations on how the assignment of intangibles intersects and how it is a big component of an enterprise’s transfer pricing system.
by Merv Edwards, published in International Tax Review, Intellectual Property (3rd Edition); No. 19, January, 2005, pp. 9-12