Adrienne Woodyard Weighs in on Glaxo Transfer Pricing Case
Source: Law Times
Published: Wednesday, 22 August 2012
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 ruling from the Supreme Court of Canada.The Canadian subsidiary of the British-based Glaxo Group and the Canada Revenue Agency (CRA) have been locked in a longstanding dispute on whether inflated prices were paid to foreign affiliates to import the substance ranitidine – an active ingredient in the ulcer drug sold under the brand name Zantac – as a way to shift profit outside of Canada.
The case has many implications for tax practitioners across Canada, and Woodyard points to the CRA's decision in not pursuing GlaxoSmithKline for the royalties paid to its parent as one of the problems confronting tax auditors should the matter be "ultimately referred back to the Tax Court for determining what a reasonable price for ranitidine would be."
This article was originally published in the August 6, 2012 edition of Law Times. It has been reproduced here with permission from the publisher.