In a lengthy judgment released on May 30, 2008, the Tax Court of Canada in GlaxoSmithKline Inc. v. The Queen considered whether the price paid by the taxpayer to a related Swiss company for ranitidine, the active pharmaceutical ingredient in ulcer medication sold in Canada by the taxpayer under the brand name Zantac, was “reasonable in the circumstances” under subsection 69(2) of the Income Tax Act (Canada), a predecessor provision to the current transfer pricing rules in section 247 of the Act.

type Tax News - June 2008 - Canada's Tax Court Decides First Transfer Pricing Case