International transfer pricing

The theatres for sport, celebration sites, cultural programs, and other elements associated with making the 2010 Winter Games an exceptional experience will draw on Canadian talent and expertise from abroad. As a result, goods and services will be exchanged across borders in all kinds of international transactions.

International transfer prices are the prices at which services and property are traded across international borders between related parties (e.g., a contract between two corporations wholly-owned by the same individual). Canada's income tax laws contain provisions that determine the tax consequences associated with failing to price goods and services at their fair market value.

For information on how Canada's transfer pricing rules are applied, see IC 87-2R, International Transfer Pricing, and IC-94-4R, International Transfer Pricing: Advance Pricing Arrangements (APAs).