It's a fairly complex determination. The rules in the Income Tax Act are actually not that long, but there's a tremendous amount of guidance done through the Organisation for Economic Co-operation and Development and transfer pricing guidelines put out by the Canada Revenue Agency.
Ultimately, the Income Tax Act essentially provides that you have to use arm's-length prices, and then there's a broader mechanism that's used for determining what those arm's-length prices are. For example, companies are required to have contemporaneous documentation in order to establish how they came up with their arm's-length prices. Companies engaged in cross-border transactions will often keep that kind of contemporaneous documentation to show their transfer pricing methodologies.
The Canada Revenue Agency can, of course, come in and challenge whether or not the transfer pricing was done correctly and whether the prices should be something else. From that, of course, taxpayers can challenge an assessment with the Canada Revenue Agency, and it ultimately goes up to the courts to determine whether or not arm's-length prices were charged, and if not, what the consequences would be.