Abstract

http://ssrn.com/abstract=1953984
 


 



The McKesson Case: A Further Debate on Key Transfer Pricing Principles


Danny Beeton


Freshfields

Rupert Macey-Dare


University of Oxford - Saint Cross College

November 3, 2011

Transfer Pricing Week, 2011

Abstract:     
The trial of McKesson Canada Corporation v. The Queen commenced in the Tax Court of Canada in Toronto on 17 October 2011 and is expected to take six to seven weeks. This case concerns a related party debt factoring arrangement between McKesson Canada Corporation (McKesson) and McKesson International Holdings III S.A. R.L. (the factor) resident in Luxembourg. It already appears that certain key techniques and assumptions used in this common type of tax planning arrangement have been called into question and McKesson will surely join GE Capital Canada , GlaxoSmithKline and Alberta Printed Circuits as another key source of transfer pricing case law and precedent originating from Canada. This paper considers key questions and issues currently before the court.

Number of Pages in PDF File: 7

Keywords: transfer pricing, factor, OECD, tax, Luxembourg, CUP, recourse, non-recourse, discount

JEL Classification: H20, H25, H26, H32

Accepted Paper Series


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Date posted: November 3, 2011 ; Last revised: July 25, 2012

Suggested Citation

Beeton, Danny and Macey-Dare, Rupert, The McKesson Case: A Further Debate on Key Transfer Pricing Principles (November 3, 2011). Transfer Pricing Week, 2011. Available at SSRN: http://ssrn.com/abstract=1953984

Contact Information

Danny Beeton
Freshfields ( email )
65 Fleet Street
London EC4Y 1HS
United Kingdom
Rupert Macey-Dare (Contact Author)
University of Oxford - Saint Cross College ( email )
Saint Giles
Oxford
United Kingdom
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