Canada uses Berry Ratio to test profit margins.

Australasian Business Intelligence, October, 2005

Byline: Martin Przysuski and Srini Lalapet

Oct 10, 2005 (Tax Notes International - ABIX via COMTEX) -- The Canada Revenue Agency (CRA) is increasingly making use of the Berry Ratio in its transfer pricing audits of Canadian distributors. The Berry Ratio, which was devised by Charles H Berry of Princeton

University and which looks at the ratio of gross profit to operating expenses, is also used in the US and can be found in section 482 of the Internal Revenue Code. The ...