Adrienne Woodyard Comments on Transfer Pricing Audits in Canadian Lawyer Magazine
Source: Canadian Lawyer
Published: Wednesday, 6 February 2013
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.