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ARTICLE · 13 APRIL 2026

Bill C-15 Receives Royal Assent: What It Means For Canada’s Transfer Pricing Rules

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On March 26, 2026, Bill C-15 (Budget 2025 Implementation Act, No. 1) received Royal Assent, bringing into force significant amendments to Canada’s transfer pricing rules under section 247 of the Income Tax Act.

CanadaTax
Siwei Chen
Siwei Chen
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On March 26, 2026, Bill C-15 (Budget 2025 Implementation Act, No. 1) received Royal Assent, bringing into force significant amendments to Canada’s transfer pricing rules under section 247 of the Income Tax Act. These changes have been anticipated since Budget 2025 was released in November 2025, but Royal Assent marks the point at which the proposals become binding law and provides certainty as to how transfer pricing audits and disputes will be approached going forward.

While the amendments are often described as a major shift, their significance lies less in the introduction of new concepts and more in how Parliament has reshaped the legal framework governing their application.

What you need to know about Bill C-15

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