TPM-02R Secondary Transfer Pricing Adjustments, Repatriation and Part XIII Tax Assessments 1 June 2021

Scope of secondary adjustments

• Where a taxpayer (including for TPM-02R purposes, a partnership) is subject to a “primary adjustment” under...

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Secondary adjustments arise at year end

• Although s. 15(1) or 56(2) benefits are deemed by s. 214(3.1) to be paid at the time of the event or...

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Requirements of CRA repatriation policy

• CRA will apply the following administrative repatriation policy to all taxpayers (not only those to whom...

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Interest not applied if repatriation agreement accepted

35. Subsection 247(14) of the ITA provides that if the non-arm’s length non-resident...

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36. Where a dividend is deemed to have been paid under subsection 247(12), paragraph 227(8.5)(b) provides that no penalty for failure to deduct or...

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36. Where a dividend is deemed to have been paid under subsection 247(12), paragraph 227(8.5)(b) provides that no penalty for failure to deduct or...

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