3 February 2021 Transfer Pricing Webinar of the Canadian Tax Foundation: Panel I: Transfer Pricing Audits and Competent Authority

Policy Tabs

Summaries

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S. 247(2)(d) no longer a tool of last resort

CRA cancelled IC 87-2R “International Transfer Pricing” as it was misleading regarding...

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Canada uses CbC data only for risk assessment (including, sometimes, at the field audit level)

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CASD does not share its APA paper with the taxpayer before submitting it to the other Treaty partner

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Downward adjustments generally not granted if double non-taxation results

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COVID residency relief has not been extended

CRA’s COVID-related guidance on corporate residency, permanent establishments, and other similar...

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TPM-17 maintained re CEWS subsidies

Notwithstanding somewhat different views of the OECD, CRA will continue to evaluate transfer prices in...

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Meaning of TPRC insufficient documentation notation

The Transfer Pricing Review Committee typically indicates that “the documentation provided...

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