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January 2005 Issue

Bulletin

NEW TRANSFER PRICING RULES

Article 43-1 of the Income Tax Act provides for an adjustment mechanism for related parties' transaction that do not conform to regular busi-ness practices. However, in the past three dec-ades, this provision has rarely been used, mainly because of a lack of official criteria by which to determine what constitutes irregular business practices. The issue of how profits are distrib-uted between entities in different countries ... More

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