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ARTICLE · 19 NOVEMBER 2019

Can An Auditor Compel A Taxpayer To Create Documents?

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In the Minister of National Revenue v. Amdocs Canadian Managed Services Inc. 2015 FC 1234, it was contemplated whether or not the Minister of National Revenue

CanadaAccounting and Audit
Joseph Takhmizdjian
Joseph Takhmizdjian
Noah Weinstein
Noah Weinstein
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In the Minister of National Revenue v. Amdocs Canadian Managed Services Inc. 2015 FC 1234, it was contemplated whether or not the Minister of National Revenue (Minister) could issue a compliance order to a taxpayer, compelling the taxpayer to create and provide information pursuant to section 231.7 of the Income Tax Act (ITA) when the taxpayer had proven that it did not possess such information.

Facts

Amdocs Canadian Managed Services Inc. (ACMS) was a Canadian taxpayer, incorporated under the Canada Business Corporations Act, and was a member of the Amdocs Group, a multinational corporation with establishments across the world.

In 2013, the Canadian Revenue Agency (CRA) initiated a transfer-pricing audit on ACMS. In light of this audit, the CRA issued numerous queries, of which three represented grounds for a compliance order. These three queries, which became the subject of the dispute in question, were as follows:

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