Canada: APA Report and MAP Report 2014-2015Par Robert Robillard - 3 septembre 2015
This blogpost originally appeared on rbrt.ca.
Available both in English and French, the Mutual Agreement Procedure (MAP) Report and Advance Pricing Arrangement (APA) Program Report were recently released by the Canada Revenue Agency.
CRA MAP results for 2014-2015 are as follow:
« Of the 170 MAP cases that were resolved in fiscal year 2014-2015, 115 cases were categorized as negotiable, which means that bilateral negotiations with another tax administration were required to resolve an issue. Of the 115 cases negotiated with other tax administrations, 94% (109 cases) of taxpayers who sought assistance obtained full relief from double taxation, 3% (3 cases) obtained partial relief, and 3% (3 cases) did not obtain relief. »
« Non-negotiable cases are resolved by an agreement between Canada’s Competent Authority and specific taxpayers, and do not involve another tax administration. »
As we keep repeating, the number of double tax cases is indeed on the rise.
MAP Cases profile:
|Fiscal Year||Beginning Inventory||Accepted||Completed||Ending Inventory|
|2014 – 2015||344||347||170||521|
|2013 – 2014||315||309||280||344|
|2012 – 2013||312||279||276||315|
|2011 – 2012||254||371||313||312|
|2010 – 2011||243||136||125||254|
MAP cases are usually initiated by Canada, as seen below:
|Fiscal Year||Foreign – initiated Audit Adjustments||Canadian – initiated Audit Adjustments||Total|
The library on Transfer Pricing in Canada is available here.
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