Matias Milet, Jennifer Horton, "The Canada Revenue Agency’s Interpretation of the 2017 OECD Transfer Pricing Guidelines", International Tax (Wolters Kluwer CCH), No. 103, December 2018, p.10

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

CRA intent to apply the 2017 Transfer Pricing Guidelines to pre-2017 taxation years (pp. 10-11)

The CRA indicated [in 2018 CTF Rouundtable, Q.4]...

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Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 9

The OECD 2017 Transfer Pricing Guidelines reoriented transfer pricing towards the concept of value creation, namely, of ensuring that profits are...

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