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Canada Case Law

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Tax law 2020 FC 750

Bayer Inc. v. Canada (Attorney General)

The Federal Court held that the CRA’s foreign-information requirement was procedurally fair but unreasonable, and varied it to restore earlier limits.

  • Foreign-based information requirement
  • Income tax act s.231.6
  • Transfer pricing
  • Reasonableness review
  • Procedural fairness
  • Judicial-review
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Tax law 2013 FC 291

Soft-Moc Inc. v. Canada (National Revenue)

The Federal Court upheld a foreign-based information requirement under s. 231.6 of the Income Tax Act in a transfer pricing audit and dismissed the judicial review.

  • Foreign-based information requirement
  • Section 231.6 income tax act
  • Transfer pricing
  • Relevance of documents
  • Confidentiality of third party information
  • Standard of review - reasonableness
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Canada decisions are organised by court, judge, legal area and indexed issue so a practitioner can move from a proposition to a citable authority with the surrounding context intact.