International Top 30 position: 4

McKesson: appellant’s factum filed

By Shaira Nanji

On 10 January 2014, McKesson Canada Corporation appealed the decision of the Tax Court of Canada in McKesson Canada Corporation v The Queen (2013 TCC 404).

In McKesson, the Tax Court upheld the Canada Revenue Agency’s transfer price adjustments (made pursuant to section 247 of the Income Tax Act [Canada]) that had reduced the discount rate paid under a receivables sales agreement between McKesson Canada and its parent company, MIH, from 2.206 per cent to 1.013 per cent. The Tax Court also upheld the assessment of withholding tax on a deemed dividend that arose in a secondary adjustment resulting from the lower discount rate…

Click on the link below to read the rest of the Dentons briefing.

Briefings from Dentons

View more briefings from Dentons

Analysis from The Lawyer

View more analysis from The Lawyer


1 Fleet Place

Turnover (€m): 209.5
Lawyers: 760
Partners: 183
Jurisdiction: Europe