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ARTICLE · 29 JUNE 2023

Finance Canada Proposes Largest Overhaul Of Canadian Transfer Pricing Legislative Framework

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This article discusses the Department of Finance Canada's proposed legislative changes to section 247 of the Income Tax Act (Act), introduced to eliminate certain perceived issues with the current legislation...

CanadaTax
Pierre Alary
Pierre Alary
André Bergeron
André Bergeron
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This article discusses the Department of Finance Canada's proposed legislative changes to section 247 of the Income Tax Act (Act), introduced to eliminate certain perceived issues with the current legislation and align Canada's transfer pricing rules with the current international consensus.

The recent decision in Her Majesty The Queen v Cameco Corporation (Cameco) likely expedited the need, in Finance Canada's view, for legislative changes. This decision was significant, as Cameco was the first Canadian case to consider the recharacterization rules in subsections 247(b) and (d) of the Act and set a precedent that impacted both legislative and administrative aspects of transfer pricing.

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