CRA indicates that BEPS 13 has no effect on the s. 247 documentation requirements

CRA indicated that BEPS Action Item 13 had been dealt with by the introduction of proposed s. 233.8 (respecting country-by-country reporting), which does not include a requirement to produce a Local File or a Master File and has no direct relation to s. 247 (including the contemporaneous documentation requirement in s. 247(4)). CRA stated that Action 13 thus has not altered its criteria regarding whether a taxpayer has made reasonable efforts to determine and use arm’s length transfer pricing.

Neal Armstrong. Summary of 29 November 2016 CTF Annual Roundtable, Q.9 under s. 247(4).