The commercial transactions between two companies belonging to the same group have to be made on the basis of the arm lengths principle.

Where transfer pricing in particular is concerned, it may be difficult to obtain after the fact the necessary evidence that internal group transactions have been effected in accordance with the arms-length principle.

Consequently, the objective of transfer pricing experts is to determine what is the “arm’s length price” or “market price” is for any particular situation.

There are no arm’s-length prices, no competitive markets, to which a firm can refer.

It states that quoted prices, such as those from a commodity exchange market, may be useful in determining arm’s length prices.

However, no single method is enough to determine effectively the arm’s length price from all the transactions subjected to the issue of transfer pricing.

Through that procedure, the two States will be able to agree on the same arm’s length price, which may be one of the prices put forward by the taxpayer and the two States or a different one.

Such presumptive evidence may be subject to rebuttal, however, if it can be demonstrated that it does not affect the accurate determination of the arm’s length price.

What is arrived at after adding the cost plus mark up to the above costs may be regarded as an arm’s length price of the original controlled transaction.

In that regard, the Commission considered that a gross margin of [confidential]% for SCTC constituted an arm’s length price for the purchase of the coffee beans.

Moreover, depending on the facts and circumstances of the taxpayer, not all methods approximate a market outcome in a correct way.

This payment has to be at arm’s length to ensure that profits (or losses) are allocated among the different parts of the group in a fair and sound manner.

This revenue (which is based on arms-length pricing) and the related profit is then eliminated through an intercompany adjustment that is included within the “Eliminations & other” line.

This revenue (which is based on arms-length pricing) and the related profit is then eliminated through an intercompany adjustment that is included within the "Eliminations & other" line.

In the initial assessments and proposal letters from CRA, Cameco did not see any indication as to what terms and conditions or arm’s-length prices the contracts should have had.