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ARTICLE · 12 SEPTEMBER 1997

New Canadian Transfer Pricing Legislation Issued

PwC Management Services LP
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CanadaAccounting and Audit

PLEASE NOTE: THIS INFORMATION WAS ORIGINALLY SUBMITTED BY COOPERS & LYBRAND, CANADA

On September 11, 1997, the Canadian government issued the long-awaited draft legislation relating to the transfer pricing measures announced in their February 1997 budget. Also released was a revised circular outlining Revenue Canada's administrative practices in the transfer pricing area.

This legislation includes the new contemporaneous documentation requirements and imposes a significant penalty for those who do not determine and use arm's-length transfer prices. It is anticipated that the legislation, generally effective for tax years beginning after 1997, will be tabled in Parliament before year end. Therefore, only comments on the proposals received before November will be considered by the tax authorities.

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