The McKesson Case: A Further Debate on Key Transfer Pricing Principles
University of Oxford - Saint Cross College
November 3, 2011
Transfer Pricing Week, 2011
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, H32Accepted Paper Series
Date posted: November 3, 2011 ; Last revised: July 25, 2012
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