CRA adopts 2010 OECD Transfer Pricing Guidelines

After noting some of the changes in the 2010 version of the OECD Transfer Pricing Guidelines as contrasted to the 1995 version, CRA  stated that it "endorses the application of the arm's length principle and the 2010 version of the TPG for the administration of the Income Tax Act in transfer pricing matters."

Although it would have been astonishing for CRA to reject the 2010 Guidelines, it nonetheless is useful to have this written confirmation.

Neal Armstrong.  Summary of 2011 TEI Roundtable, Q. 12 2011-0427311C6 under s. 247(2).