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ARTICLE · 16 DECEMBER 2025

Budget 2025 Proposal Aims To Stop Taxpayers From Backdating Transfer Pricing Documentation Upon A CRA Audit

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Canada's 2025 federal budget introduced long-anticipated amendments to Canada's transfer pricing rules following a consultation process initiated in June 2023.

CanadaTax
André Bergeron
André Bergeron
Pierre Alary
Pierre Alary
Jim Wilson
Jim Wilson
Dale Hill
Dale Hill
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Canada's 2025 federal budget introduced long-anticipated amendments to Canada's transfer pricing rules following a consultation process initiated in June 2023. These measures represent the most significant modernization of section 247 of the Income Tax Act since its introduction in 1998. While many changes were anticipated, a new condensed deadline for providing contemporaneous documentation comes as a surprise.

This administrative measure reduces the documentation response period from three months (approximately 90 days) to 30 days, and carries significant implications for Canadian taxpayers. Below, we examine the impact of this proposed shift.

Current transfer pricing documentation regime in Canada

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