Brian Mustard, Sam Maruca, Charles Thériault, Richard Tremblay, "Transfer Pricing: What Are 'Reasonable Efforts,' and When should Penalties Apply?", Canadian Tax Foundation, 2015 Conference Report, 32:1-33

Summary Under
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2)

Alignment with OECD Guidelines (pp. 32:2-3)

[N]o Canadian legislation could explicitly refer to [the OECD] guidelines, nor indeed to any other...

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Summary Under
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(3)

Unlikelihood of a s. 247(4)(a) safe harbour (p. 32:7)

[T]he qualitative assessment of the adequacy of the actions described in subsection 247(4)...

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Words and Phrases
reasonable efforts
Summary Under
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(4) - Paragraph 247(4)(a)

Minor subsequent corrections (p. 32:8)

[I]t may, of course, happen that a transfer-pricing report is substantially completed by the...

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