{"id":"W4396666214","doi":"10.59403/121sv1t035","title":"Chapter 35: Canada: Transfer Pricing Adjustment after a Competent Authority Agreement: Sifto Canada Corp. v. The Queen","year":2019,"lang":"en","type":"book-chapter","venue":"Tax treaty case law around the globe.","topic":"Taxation and Legal Issues","field":"Business, Management and Accounting","cited_by":0,"is_retracted":false,"has_abstract":true,"ca_institutions":"","funders":"","keywords":"Queen (butterfly); Transfer (computing); Transfer pricing; Political science; Economics; Law; Computer science; Zoology; Biology","routes":{"ca_aff":false,"ca_fund":false,"ca_venue":false,"about_ca":true,"invisible_to_affiliation_only":true},"retraction":null,"screen":null,"direct_labels":[],"prediction":{"model_version":"codex-gemma-dda1882f352a","candidate_categories":["metaepi_narrow","insufficient_payload"],"consensus_categories":[],"category_scores_codex":[0.0002850718,0.0008502897,0.0007026329,0.00007133541,0.0007595234,0.0004336079,0.0005454384,0.0001913842,0.002298646],"category_scores_gemma":[0.00001084581,0.0005228273,0.0002725542,0.00008798765,0.000186833,0.0003523246,0.0002315318,0.000631386,0.0002369634],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.0008226593,"about_ca_system_score_gemma":0.0005713055,"about_ca_topic_candidate":true,"about_ca_topic_consensus":true,"about_ca_topic_score_codex":0.9982536,"about_ca_topic_score_gemma":0.9994926,"domain_scores_codex":[0.9968966,0.00003319277,0.0006808841,0.000683523,0.001063147,0.0006426347],"domain_scores_gemma":[0.9981043,0.0001250617,0.0004256105,0.00104784,0.0002274823,0.00006974315],"domain_codex":null,"domain_gemma":null,"domain_candidate":null,"domain_consensus":null,"study_design_codex":"theoretical_or_conceptual","study_design_gemma":"not_applicable","study_design_scores_codex":[0.0001294754,0.00003429636,0.000117578,0.0001723179,0.0004725985,0.002225987,0.0001382831,0.000089819,0.000001278633,0.9806376,0.01397769,0.002003084],"study_design_scores_gemma":[0.0006143829,0.00001964833,0.0004176573,0.0002052117,0.0008103288,0.0001305109,0.0002685471,0.0002079816,0.000004099252,0.001346015,0.9952838,0.0006917789],"study_design_candidate":"not_applicable","study_design_consensus":null,"genre_codex":"other","genre_gemma":"empirical","genre_scores_codex":[0.01024863,0.002740178,0.0000430988,0.008742942,0.002683821,0.002625111,0.0006524472,0.0001256579,0.9721381],"genre_scores_gemma":[0.8198263,0.00003826839,0.000003967554,0.01018673,0.002190806,0.00004279061,0.0001518668,0.00008803015,0.1674712],"genre_candidate":"other","genre_consensus":null,"teacher_disagreement_score":0.9813061,"threshold_uncertainty_score":0.9997223,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.01410342685951019,"score_gpt":0.1894295544209333,"score_spread":0.1753261275614231,"validation_status":"score_only:v0-immature-baseline","note":"Baseline scores from an immature model (maturity gate not passed). Scores rank; they never assert a category."}}