In subsection 247(2) of the Income Tax Act, the transfer pricing adjustment rules apply if transactions undertaken by non-arm’s length parties do not reflect arm’s length terms and conditions. In “McKesson Canada Corporation v. The Queen”, Tax court found that other method was the most appropriate method regarding the appropriate pricing of risk than those set out in the OECD Guidelines to use. McKesson was the first prior transfer pricing decision to be published in Canada since the Supreme Court of Canada’s decision regarding Canada v. GlaxoSmithKline Inc. At last, McKesson Canada filed a notice to appeal the Tax Court’s ruling to the Federal Court of Appeal.
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