CRA indicates that COVID-related government assistance is not subject to special treatment under TPM-17

TPM-17 provides:

When a cost-based transfer pricing methodology is used to determine the transfer price of goods, services, or intangibles sold by a Canadian taxpayer to a non-arm's length non-resident person and the Canadian taxpayer receives government assistance, the cost base should not be reduced by the amount of the government assistance received, unless there is reliable evidence that arm's length parties would have done so given the specific facts and circumstances.

CRA indicated that COVID-related government assistance is treated the same as other government assistance insofar as TPM-17 is concerned.

Neal Armstrong. Summary of 2020 IFA-YIN Seminar on COVID-19 Guidelines, Q.12 under s. 247(2)(a).