CRA notes that the pandemic has not changed Treaty time limitations

Respecting the pandemic effect on various CRA international programs, CRA indicated:

• CRA has been dealing with its counterparts on APA and MAP matters using teleconferencing and, where possible, video-conferencing; and some MAP cases were recently closed. Members of the Transfer-Pricing Review Committee have also been meeting through teleconferencing.
• Bill C-20 (re domestic time limits) does not apply to treaty time limits. If there is none, the usual domestic limits apply, e.g., under s. 152, subject to Bill C-20, which extended those limits for up to six months, but to no later than December 31, 2020.

Neal Armstrong. Summary of 15 September 2020 IFA Roundtable, Q.4 under Treaties - Article 26.