CRA Audit Settlements: Is That A Real Thing?

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Many taxpayers assume that once a CRA auditor starts an Audit, the Audit needs to be completed, with no opportunity to reach an early settlement on contentious issues. To the contrary, CRA has recently confirmed that many Audits can, in fact, be settled – albeit only after being subject to additional internal review before becoming final.

In the Tax Audit Series below, we review the CRA’s Audit Settlement Process, including CRA’s internal approval processes for settlements and the role played by its Audit File Resolution Committee ("AFRC") in significant or precedent-setting cases.

CRA’s Internal Audit Settlement Process

At a recent industry roundtable, CRA confirmed and explained that, as part of its commitment to supporting the efficient resolution of tax disputes and promoting Audit quality, settlement decisions do not always rest with the individual Auditor assigned to the file. Significant matters may require additional review through