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ARTICLE · 21 OCTOBER 2021

Canadian Transfer Pricing Update

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Canada has seen numerous transfer pricing developments throughout 2021. Canada's transfer pricing rules are summarized here under 4, Transfer Pricing.

CanadaTax
Steve Suarez
Steve Suarez
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Canada has seen numerous transfer pricing developments throughout 2021. Canada's transfer pricing rules are summarized here under 4, Transfer Pricing. For most multinationals with Canadian subsidiaries, transfer pricing constitutes the Canadian tax issue with the greatest potential exposure for challenge from the Canada Revenue Agency (CRA), which aggressively enforces Canada's transfer pricing rules in s. 247 of the Income Tax Act (Canada) (ITA).

2021 federal budget - Consultation announced

In February 2021, the Supreme Court of Canada (SCC) announced it would not hear the CRA's appeal of the taxpayer's decisive win in Canada v. Cameco Corporation, a development reviewed in our article from February 2021.

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