The Ford Motor Company of Canada case : an analysis

In an interesting case minority shareholders in a Canadian affiliated company of US-based Ford questioned the fairness of the transfer pricing system used between the two affiliated companies. The Canadian Court made some remarks regarding the tax aspects of the transfer pricing system, but mostly focused on the valuation of shares issue and held that Ford's transfer pricing policies were not at arm's length from a commercial perspective. The author explains and comments the issues at hand in detail.