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ARTICLE · 27 MARCH 1997

New Transfer Pricing Penalties From Canada

PwC Management Services LP
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CanadaAccounting and Audit

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

It has already been widely reported that the federal government used the occasion of its 1997 budget to outline changes to Canada's transfer pricing provisions. The following paragraphs will provide additional commentary on documentation requirements and penalty provisions aimed at ensuring compliance. All Canadian companies, partnerships, trusts and individuals having business transactions with related non-residents will be affected by these new provisions.

The federal budget statement last month made it clear that Revenue Canada is serious about making taxpayers comply with the "arm's-length principle" when dealing with related non-resident companies.

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