CRA will apply changes to the OECD Transfer Pricing Guidelines retroactively

CRA will apply the revised version of the OECD Transfer Pricing Guidelines to transactions which were completed, and treaties that were concluded, before its release on July 22, 2010 "since the revisions are [only] intended to increase clarity in the application of the arm’s length principle."

Neal Armstrong.  Summary of TPM-14 under s. 247(2).