Transfer Pricing in Canada

The library on BEPS and Transfer Pricing is available here.

Transfer Pricing in Canada and International Tax in Canada

Section 247: Income Tax Act, RSC 1985, c 1 (5th Supp)

Act to implement a multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (May 28,2018)

Canada Revenue Agency on Transfer Pricing in Canada

T106 Information Return of Non-Arm’s Length Transactions with Non-Residents

IC87-2R International Transfer Pricing

RC4651 Guidance on Country-By-Country Reporting in Canada

RC4649 Country-by-Country Report

IC94-4R International Transfer Pricing: Advance Pricing Arrangements (APAs)

IC94-4RSR Special Release – Advance Pricing Arrangements for Small Businesses

CRA Audit Manual – Chapter 15 International Audit

Canada Revenue Agency’s Transfer Pricing Memoranda

TPM-01 – Referrals to the Transfer Pricing Review Committee (Archived)

TPM-02 – Repatriation of funds by Non-residents – Part XIII

TPM-03 – Downward Transfer Pricing Adjustments under Subsection 247(2)

TPM-04 – Third Party Information

TPM-05 – Contemporaneous Documentation (Archived)

TPM-05R – Requests for Contemporaneous Documentation

TPM-06 – Bundled Transactions

TPM-07 – Referrals to the Transfer Pricing Review Committee (Archived)

TPM-08 – The Dudney Decision: Effects on Fixed Base or Permanent Establishment Audits and Regulation 105 Treaty-Based Waiver Guidelines

TPM-09 – Reasonable efforts under section 247 of the Income Tax Act

TPM-10 – Advance Pricing Arrangement Rollback (Archived)

TPM-11 – Advance Pricing Arrangement (APA) Rollback

TPM-12 – Accelerated Competent Authority Procedure (ACAP)

TPM-13 – Referrals to the Transfer Pricing Review Committee

TPM-14 – 2010 Update of the OECD Transfer Pricing Guidelines

TPM-15 – Intra-group services and section 247 of the Income Tax Act

TPM-16 – Role of Multiple Year Data in Transfer Pricing Analyses

TPM-17 – The Impact of Government Assistance on Transfer Pricing

Canada Revenue Agency on International Taxation in Canada

IC71-17R5 Guidance on Competent Authority Assistance Under Canada’s Tax Conventions

Guidelines for Treaty-Based Waivers Involving Regulation 105 Withholding

Foreign reporting (T1134/T1135)

IC75-6R2 Required Withholding from Amounts Paid to Non-Residents Providing Services in Canada

IC77-16R4 Non-Resident Income Tax

IT177R2 Permanent Establishment of a Corporation in a Province

Tax Compliance in Canada

RC17 Taxpayer Bill of Rights Guide: Understanding Your Rights as a Taxpayer

Voluntary Disclosures Program

Tax Treaties In Canada

OECD: MAP Peer Review Report for Canada (September 26, 2017)

Finance Canada: Notices of Tax Treaty Developments

Finance Canada: Tax Treaties (bottom of page)

Finance Canada: Tax Information Exchange Agreements

Finance Canada: International Social Security Agreements

Finance Canada: International Social Security Agreements Forms

Canada Revenue Agency: Memorandum of Understanding (arbitration procedure)

Canada Revenue Agency: Arbitration Board Operating Guidelines – Canada – United States

Transfer Pricing Case Law in Canada (click here)

Tax Treaty Case Law in Canada (click here)

Advance pricing arrangement (APA) Program Reports in Canada

Mutual agreement procedure (MAP) program reports in Canada


Customs and Transfer Pricing in Canada

Justice Canada: Customs Act (R.S.C., 1985, c. 1 (2nd Supp.))

Canada Border Services Agency

Memorandum D13-1-3 Customs Valuation – Purchaser in Canada

Memorandum D13-3-1 Methods of Determining Value for Duty

Memorandum D13-3-2 Related Persons

Memorandum D13-4-5 Transaction Value Method for Related Persons

D Memoranda D13 – Valuation

Pacific Association of Tax Administrators (PATA)

PATA Transfer Pricing Documentation Package

PATA Transfer Pricing Documentation Package

PATA Mutual Agreement Procedure

PATA Bilateral Advance Pricing Arrangement

Foreign Affairs, Trade and Developement Canada

Negotiations, trade agreements and other agreements by Country

North American Free Trade Agreement (NAFTA)