CRA confirms that it will not adjust cross-border amounts within an arm’s length range

In TPM-16, CRA acknowledges in a transfer-pricing context that "an arm’s length range will usually be established by the CRA…[and] the CRA will not make a transfer pricing adjustment if the price or margin of a transaction is within the arm’s length range."  This is similar to the comment made in Henco in a domestic context that:

A range of value makes eminent sense. And, where a taxpayer has designated a value that ultimately is found to fall within the range of reasonable fair market value, I see no reason to disturb that figure.

However, if the figure falls outside the arm’s length range, CRA will apply an average or some other technique to pick a figure well within the range.

Neal Armstrong. Summary of TPM-16 "Role of Multiple Year Data in Transfer Pricing Analyses" under s. 247(2).