Adrienne Woodyard, a tax litigator in the Davis LLP Toronto office, was interviewed for a story on transfer pricing in the January 2013 issue of Canadian Lawyer magazine.
Addressing the implications of the Supreme Court of Canada's ruling in Canada v. GlaxoSmithKline Inc., she points out that the court has acknowledged that "transfer pricing is not an exact science" and that "context is important" in determining whether a business is adhering to legislation when pricing cross-border transactions. But while the CRA cannot "treat its own assessments as if they are written in stone," the agency is devoting significant resources to transfer pricing audits, and businesses should exercise caution to avoid penalties or being drawn into lengthy arbitrations.
"Tax lawyer Adrienne Woodyard was quoted in the August 6, 2012 edition of Law Times on a landmark case that is expected to have a significant impact on all future transfer pricing cases in Canada.
GlaxoSmithKline Inc. v. The Queen is currently awaiting..."
"A Tax Court hearing set for May 15, 2013 will seek to settle the question of Conrad Black's residency status in 2002 for tax purposes. It is part of an ongoing dispute between Mr. Black and the Canadian Revenue Agency, which alleges that he..."
"Adrienne Woodyard, of Davis LLP's Toronto office, was quoted recently in the Financial Post and Ottawa Citizen. In the article, "Court ruling clarifies tax loophole plug's use," Drew Hasselback describes a decision issued on Friday..."