Part of a comparative survey dealing with the particular constraints and opportunities connected with the relationship between transfer pricing policy and tax and business planning from both a domestic and a treaty law perspective, including foreign affiliate rules, interest deductibility and thin capitalization, other limitations, transfer pricing rules in practice, and e-commerce and sharedservice concepts. Canadian income tax rules, reflected in the Income Tax Act (Canada), the Income Tax Regulations and various administrative practices, policies and guidelines articulated by Canadian tax authorities, do not distinguish between high-tax and low-tax countries as such. Indeed, these rules apply generally to transactions and other arrangements that take place within commonly controlled groups to which the transfer pricing rules apply. However, to the extent that "transfer pricing" is understood, more comprehensively, to address situations in which members of a commonly controlled group are in a position to affect, and distort or manipulate, how the terms and conditions of transactions between and among them shift taxable income internationally, Canadian transfer pricing rules in a larger sense involve more than the main transfer pricing rule in Sec. 247 of the Act, and should be understood to include certain important elements of Canada's controlled foreign corporation rules found in the foreign affiliate regime and other rules.