January 16, 17, 2013 Toronto, Canada Join Dean Morris as he presents “Transfer Pricing Anti-Avoidance” at the Inaugural Federated Press Bulletproofing Your Tax Practice Conference.

Between 1990 and 1993, GlaxoSmithKline Inc. (“Glaxo Canada”) purchased ranitidine, the active pharmaceutical ingredient in the brand name anti-ulcer blockbuster drug Zantac, from Adechsa S.A., a related non-resident company, for between $1,512 and $1,651 per kilogram. During the same period, two Canadian generic pharmaceutical companies, Apotex Inc. (“Apotex”) and Novopharm Ltd. (“Novopharm”) purchased ranitidine from other sources for use in their generic anti-ulcer drugs for between $194 and $304 per kilogram from arm’s length suppliers.

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Inside this edition of the Transfer Pricing Monitor:

• Canada Revenue Agency (CRA) Releases their 9th Annual Report on the Mutual Agreement Procedure (MAP) Program
• The Latest on Glaxo
• Glaxo Canada’s Withholding Tax Puzzle
• CRA Releases Two new Transfer Pricing Memorandums (TPMs)