CRA Releases Revised APA Guidance

On February 21, 2024, the Canada Revenue Agency (CRA) published a revised Information Circular (Circular) on the Advance Pricing Arrangement (APA) program. The APA program offers taxpayers in multinational groups the opportunity to obtain certainty on the transfer pricing of their cross-border transactions with related parties. The changes in the Circular focus on the criteria that taxpayers must meet to be accepted into the APA program (generally requiring more information at the pre-filing stage) and how the CRA evaluates whether taxpayers and transactions are eligible for an APA to obtain certainty on their transfer pricing arrangements for future taxation years (and any rollback period).