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)
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-07 – Referrals to the Transfer Pricing Review Committee (Archived)
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
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
- Advance Pricing Arrangement Program Report 2016-2017
- Advance Pricing Arrangement Program Report 2015-2016
- Advance Pricing Arrangement Program Report 2014-2015
- Advance Pricing Arrangement Program Report 2013-2014
- Advance Pricing Arrangement Program Report 2012-2013
- Advance Pricing Arrangement Program Report 2011-2012
- Advance Pricing Arrangement Program Report 2009-2010
- Advance Pricing Arrangement Program Report 2007-2008
- Advance Pricing Arrangement Program Report 2004-2005
- Advance Pricing Arrangement Program Report 2003-2004
Mutual agreement procedure (MAP) program reports in Canada
- Mututal Agreement Procedure Program Report 2015-2016
- Mututal Agreement Procedure Program Report 2014-2015
- Mututal Agreement Procedure Program Report 2013-2014
- Mututal Agreement Procedure Program Report 2012-2013
- Mututal Agreement Procedure Program Report 2011-2012
- Mututal Agreement Procedure Program Report 2010-2011 (French)
- Mututal Agreement Procedure Program Report 2009-2010
- Mututal Agreement Procedure Program Report 2008-2009
- Mututal Agreement Procedure Program Report 2007-2008
- Mututal Agreement Procedure Program Report 2006-2007
- Mututal Agreement Procedure Program Report 2001-2004
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
Pacific Association of Tax Administrators (PATA)
PATA Transfer Pricing Documentation Package
PATA Transfer Pricing Documentation Package
Foreign Affairs, Trade and Developement Canada
Negotiations, trade agreements and other agreements by Country