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ARTICLE · 09 JUNE 2026

How To Be Audit Ready In The Face Of Canada’s New Transfer Pricing Rules

Canada’s new transfer pricing rules are in effect for tax years beginning after the 2025 federal budget (i.e., 2026 for calendar year taxpayers). It will be many years before the courts weigh in on the impact of the amendments, but the time for multinationals to ready themselves for CRA audit scrutiny is now. Below, we outline the key changes in the amendments and the practical steps that taxpayers can take today.

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Key Takeaways

  • Key changes to Canada’s transfer pricing rules include a single adjustment provision, a shift from contractual terms to actual conduct and consistency with OECD Transfer Pricing Guidelines.
  • The amendments expand documentation requirements and shorten the response time to 30 days for CRA requests, increasing compliance pressure.
  • Taxpayers should review their transfer pricing policies and intercompany agreements to ensure alignment with the new rules.

Canada’s new transfer pricing rules are in effect for tax years beginning after the 2025 federal budget (i.e., 2026 for calendar year taxpayers). It will be many years before the courts weigh in on the impact of the amendments, but the time for multinationals to ready themselves for CRA audit scrutiny is now. Below, we outline the key changes in the amendments and the practical steps that taxpayers can take today.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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