The TPSM is often inconsistent with the Canadian transfer-pricing rules

Unlike Art. 9 of the OECD Model Treaty and Code s. 482, which permit consideration of the overall commercial or financial relations between related entities, the focus in ss. 247(2)(a) and (c) on individual transactions renders it quite difficult to utilize the transactional profit split method in a Canadian context.

Neal Armstrong.  Summary of Ilana Ludwin, "Application of the Transactional Profit Split Method in Canada," Tax Management International Journal, 2015, p. 98 under s. 247(2).