Canada v. GlaxoSmithKline: Resale Price vs. CUP Method—Which Was Right for Transfer Pricing?


  • QUESTION POSTED BY: Student
  • PROGRAMME: Postgraduate Diploma in International Taxation
  • TOPIC: Transfer Pricing Extended (WEEKS 28, 29 & 30)
  • LECTURER: Okkie Kellerman

FULL QUESTION

Taking a look at the case: Canada v. GlaxoSmithKline Inc

What is your view on the transfer pricing method used (Resale Price Method) by GlaxoSmithKline Inc and the ruling by the Tax Court that the CUP method was most appropriate?

ADDITIONAL WRITTEN ANSWER

In the case of Canada v. GlaxoSmithKline Inc., the central issue was determining the appropriate transfer pricing method for transactions between GlaxoSmithKline Inc. (Glaxo Canada) and its related non-resident supplier, Adechsa S.A., concerning the purchase of ranitidine, the active pharmaceutical ingredient in the drug Zantac.

Glaxo Canada’s Use of the Resale Price Method (RPM):

Glaxo Canada employed the Resale Price Method to set its transfer prices. This approach began with the resale price of the finished product (Zantac) and subtracted a gross margin to arrive at the transfer price for ranitidine. Specifically, Glaxo Canada aimed to retain a 60% gross margin on the resale price, with the remaining 40% allocated as the transfer price for ranitidine. For example, if Zantac was sold for $10, the transfer price for ranitidine would be set at $4, allowing Glaxo Canada to retain a 60% gross margin.

Take a look at our case summary on this:  

https://academyoftaxlaw.com/glaxosmithkline-transfer-pricing-case-canada/

Tax Court’s Preference for the Comparable Uncontrolled Price (CUP) Method:

The Tax Court of Canada favored the Comparable Uncontrolled Price method, which compares the price charged in a controlled transaction to the price charged in a comparable uncontrolled transaction between independent entities. The court compared the prices Glaxo Canada paid for ranitidine to those paid by Canadian generic pharmaceutical companies, such as Apotex Inc. and Novopharm Ltd., which purchased ranitidine from arm’s length suppliers at significantly lower prices. The court concluded that the prices paid by Glaxo Canada were higher than what would have been reasonable in an arm’s length transaction.

Analysis and Supreme Court Ruling:

The Supreme Court of Canada later addressed this issue, emphasizing that transfer pricing is not an exact science and that the selection of the most appropriate method depends on the specific circumstances of each case. The Court noted that the CUP method is often preferred when there are sufficiently comparable uncontrolled transactions. However, in this case, the Court found that the Tax Court erred by not considering the License Agreement between Glaxo Canada and its parent company, which granted rights to use trademarks and patents, thereby affecting the comparability of transactions. The Supreme Court remitted the matter back to the Tax Court for reconsideration, instructing it to take into account all relevant circumstances, including the License Agreement, to determine the appropriate transfer price.

Glaxo Canada’s use of the Resale Price Method was based on its business model and the specific circumstances of its operations, including the rights and benefits conferred by the License Agreement. The Tax Court’s initial preference for the CUP method did not fully account for these factors, leading the Supreme Court to call for a more comprehensive analysis. This case underscores the importance of considering all relevant circumstances and agreements when selecting the appropriate transfer pricing method, as rigid adherence to a single method may not yield an arm’s length result in complex, interrelated transactions.


VIDEO SCRIPT

The case of Canada v. GlaxoSmithKline Inc. revolves around the appropriate transfer pricing method for transactions between GlaxoSmithKline Canada (Glaxo Canada) and its related non-resident supplier, Adechsa S.A. 

The dispute specifically focused on the price paid by Glaxo Canada for ranitidine, the active ingredient in the drug Zantac, and whether that price reflected an arm’s length value.

I will provide you with a link to our full case summary on this.

Glaxo Canada employed the Resale Price Method, or RPM, to determine its transfer prices. This method starts with the resale price of the finished product—in this case, Zantac—and subtracts a gross margin to arrive at the transfer price for the raw material, ranitidine. 

Glaxo Canada aimed to retain a 60% gross margin on the resale price of Zantac, allocating the remaining 40% to the cost of ranitidine. For example, if Zantac sold for $10, the transfer price for ranitidine would be $4, leaving Glaxo Canada with a 60% margin.

The Tax Court of Canada, however, took issue with this approach and concluded that the CUP method was the more appropriate choice. 

The CUP method compares the price charged in the controlled transaction with prices observed in comparable transactions between independent parties. In this case, the Tax Court compared the prices Glaxo Canada paid for ranitidine to those paid by generic pharmaceutical companies in Canada, such as Apotex and Novopharm. 

These companies purchased ranitidine from independent suppliers at much lower prices than Glaxo Canada. 

Based on this comparison, the court found that Glaxo Canada was paying significantly more than what would have been reasonable in an arm’s length transaction.

However, the story doesn’t end there. The case was taken to the Supreme Court of Canada, which acknowledged that transfer pricing is not an exact science. 

The Court emphasized that the selection of the most appropriate method depends on the specific circumstances of each case. In reviewing the Tax Court’s analysis, the Supreme Court pointed out a critical oversight: the Tax Court had failed to consider the broader business context, particularly the License Agreement between Glaxo Canada and its parent company. 

This agreement granted Glaxo Canada the rights to use trademarks, patents, and other intangible assets associated with Zantac, which likely influenced the pricing of ranitidine.

The Supreme Court did not decide whether the CUP method or the Resale Price Method was the correct approach but instead sent the case back to the Tax Court for reconsideration. It instructed the lower court to factor in all relevant agreements and circumstances, including the License Agreement, to arrive at a transfer price that better reflects the arm’s length principle.

This case highlights several important points about transfer pricing

Glaxo Canada’s use of the Resale Price Method was based on its specific business model and the unique benefits conferred through its License Agreement. 

The Tax Court’s preference for the CUP method was understandable, given the seemingly stark price difference between Glaxo Canada’s ranitidine purchases and those of generic competitors. 

However, the Supreme Court’s intervention underscores that comparability is not just about finding similar transactions; it also requires a deeper analysis of the contractual and business framework that influences pricing.

Ultimately, the GlaxoSmithKline case illustrates the complexities of selecting a transfer pricing method. It shows that rigidly applying a single method without fully considering the business context can lead to flawed conclusions. 

As practitioners, this serves as a reminder to evaluate all relevant factors, agreements, and circumstances when determining arm’s length prices in related-party transactions.