CRA indicates that a non-commercial arrangement (low rent to a relative) is not subject to the transfer-pricing rules

Where a non-resident individual not carrying on business in Canada leases a Canadian property to a related resident individual at less than fair market value rent, there will be no Part XIII tax exigible on imputed rent in excess of that paid because "the transfer pricing rules in section 247… would generally not be applied to adjust the amount of rent under the circumstances." However, municipal taxes (but not utilities) paid by the tenant will be treated as amounts or credited to the non-resident for the use of the property.

Although rents from a rental property which is not a source of income are not required to be reported for Part I purposes by a resident recipient, rents from such a property nonetheless are subject to Part XIII tax when paid to a non-resident.

Neal Armstrong. Summary of 3 October 2014 Memo 2014-0532051I7 under s. 212(1)(d).