The Transfer Pricing Audit: 2026 Transfer Pricing Guide – Part 2

A Practical Guide to Canadian Transfer Pricing examines the full transfer pricing lifecycle, from pricing and documentation through to audits, disputes, and cross‑border relief.

Explore other chapters in the guide:

Transfer Pricing Audit Considerations

Requests for Contemporaneous Documentation

A transfer pricing audit will commence with the issuance of an initial contact letter, wherein the CRA will inform the taxpayer that it is under audit and request for copies of the taxpayer’s contemporaneous documentation. Separate requests for contemporaneous documentation will be issued to the taxpayer for each taxation year or fiscal period under audit. If, during the course of the audit, the auditor uncovers additional transactions which it was not initially aware of, the auditor must issue a request for contemporaneous documentation for these previously unknown transactions.