27 February 2024 CTF Transfer Pricing Roundtable

Policy Tabs

Summaries

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Consistent with the transfer-pricing guidelines (TPG), the delineation process requires outlining what has...

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Not much has changed, although there is less pushback from taxpayers on CRA doing functional interviews. Once the...

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The CbC information is being shared with auditors in the field and is being used in CRA’s risk assessment...

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Summary Under

In its supporting documentation the taxpayer should not simply state that agreements with third parties were reviewed and none were...

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