A Comparison of Transfer Pricing Practices in Canada and China
Odette M. Pinto

Abstract
Multinational corporations, as well as countries around the world, regard transfer pricing as one of the most important challenges they face. There has been a substantial increase in foreign direct investment between China and Canada in the past two decades, with an increase in transfer pricing concerns. This qualitative study compares the transfer pricing practices in Canada and China, including an examination of the practices for intangible property. The results indicate that although the Organization for Economic Cooperation and Development issues global transfer pricing guidelines, the choice of transfer pricing practices in a country is dependent on its economic development, and its culture, political and economic systems. In particular, this study finds that transfer pricing for intangibles is a contentious issue, with uncertainty about the definition and the valuation of intangible assets.

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