Chapter 35: Canada: Transfer Pricing Adjustment after a Competent Authority Agreement: Sifto Canada Corp. v. The Queen

Why this book? This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 35 most important tax treaty cases that were decided around the world in 2017. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2018 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics. Downloads Sample excerpt, including table of contents This book is part of the Tax Treaty Case Law around the Globe Series View other titles in the series Editor(s) Eric C.C.M. Kemmeren, professor of international tax law and international taxation and Chairman of the Tax Economics Department of the Fiscal Institute Tilburg of Tilburg University, the Netherlands, and member of the board of the European Tax College. Peter Essers, professor of tax law and Chairman of the Tax Law Department of the Fiscal Institute Tilburg of Tilburg University, the Netherlands, and member of the board of the European Tax College. Daniël S. Smit, professor at the Fiscal Institute Tilburg of Tilburg University, the Netherlands. Cihat Öner, associate professor at the Fiscal Institute Tilburg of Tilburg University, the Netherlands. Michael Lang, professor and Head of the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Jeffrey Owens, professor and Head of the Global Tax Policy Center at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Pasquale Pistone, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business), associate professor at the University of Salerno, Italy, and Academic Chairman of IBFD. Alexander Rust, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Josef Schuch, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Claus Staringer, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Alfred Storck, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Contributor(s) Ricardo García Antón, Paolo Arginelli, Philip Baker, Michael Beusch, Yariv Brauner, Graeme Cooper, Tsilly Dagan, David G. Duff, Craig Elliffe, Peter Essers, Søren Friis Hansen, Guilherme Galdino, Werner Haslehner, Roland Ismer, Eric C.C.M. Kemmeren, Guglielmo Maisto, Christoph Marchgraber, Adolfo Martín Jiménez, João Félix Pinto Nogueira, Cihat Öner, Lysandre Papadopoulos, Katerina Perrou, Cees Peters, Marilyne Sadowsky, Luís Eduardo Schoueri, D.P. Sengupta, Daniël S. Smit, Mirna Solange Screpante, A.J.A. Ton Stevens, Karolina Tetłak, Anne Van de Vijver.

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