Who we are

Where a person considers that the actions of Canada or a treaty partner result or may result in taxation not in accordance with a particular treaty, the person may request competent authority assistance. Assistance by the competent authority is generally provided under the mutual agreement procedure (MAP) article contained in Canada's tax treaties.

Canada's income tax treaties define the Canadian competent authority as the Minister of National Revenue or the Minister's authorized representatives.

What we do

The competent authority

• resolves double taxation cases; and
• negotiates advanced pricing arrangements.

The competent authority also

• resolves issues concerning the application of tax treaties generally where specific taxpayers are not involved and interpretive issues involving treaty partners;
• considers the recognition of foreign pension plans allowed under certain treaties; and
• considers applications under paragraph 6, of Article XXIX A (Limitation on Benefits) in the Canada-US Tax Convention.

For more details, refer to IC71-17, Guidance on Competent Authority Assistance Under Canada's Tax Conventions.

Contact us

For more information regarding double taxation cases, advance pricing arrangements, and elections with respect to U.S. Roth Individual Retirement Accounts (Roth IRAs), contact us at:

International and Large Business Directorate
Competent Authority Services Division
344 Slater Street
18th Floor, Canada Building
Ottawa ON K1A 0L5

email: CPMAPAPAG@cra-arc.gc.ca

Office of the Director – Competent Authority Services Division

Jennings, Michael – Director, 343-551-1343

Mutual Agreement Procedure – Advance Pricing Arrangement

Section 1: Paul, Jennifer – Manager, 438-337-5823
Section 2: Nemeth, Jaime – Manager, 416-458-2173
Section 3: McSpaden, Chuck – Manager, 873-455-2832
Section 4: Zappavigna, Antonio – Manager, 343-551-9002

Mutual Agreement Procedure – Technical Cases

Tarres, Ana-Maria – Manager, 819-775-2194

For more information concerning the application of tax treaties where specific taxpayers are not involved, non-discrimination, recognition of foreign pension plans under treaties, and consideration of requests under paragraph 6, of Article XXIX A (Limitation on Benefits) in the Canada-US Tax Convention, contact us at:

Competent Authority Policy and Treaty Advisory Section
International Relations and Treaties Office
Legislative Policy Directorate
Legislative Policy and Regulatory Affairs Branch
6th Floor, Tower A
Place de Ville
320 Queen Street
Ottawa ON K1A 0L5

Email: CA.IRTO-AC.BRCI@cra-arc.gc.ca