The CRA's New Power To Compel Oral Interviews

The Canada Revenue Agency (CRA) can now require taxpayers or any other person to answer "all proper questions" and provide all reasonable assistance for any purpose relating to the administration or enforcement of the Income Tax Act (ITA), including by submitting to oral questioning at a place designated by the CRA.¹

In this bulletin, we comment on the scope of the CRA's new power to compel oral interviews, which became effective on December 15, 2022.

Background

Although it is not standard audit practice for the CRA to demand that taxpayers and their agents submit to oral interviews in the course of tax audits, the CRA will sometimes do so, especially during transfer pricing audits and, more recently, during audits initiated under the related-party initiative (RPI). Such a CRA demand was recently considered in Minister of National Revenue v Cameco Corporation² (Cameco), in which the Federal Court of Appeal (FCA) held that, although oral interviews are not