Canadian Court Holds Canadian Authority May Not Make Transfer Pricing Adjustment following MAP Resolution with U.S.

In its decision, dated 10 March 2017, the Tax Court of Canada ruled on whether the Canada Revenue Agency (CRA) may make a transfer pricing adjustment in relation to a transaction that was already adjusted in the U.S. as part of a MAP resolution.

The case involved Sifto Canada Corp. (Sifto), which is engaged in the mining and sale of various salt products, including the sale of rock salt to a related U.S. corporation, North American Salt Company (NASC). For the years 2002 to 2006, Sifto and…