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ARTICLE · 01 JUNE 2026

Transfer Pricing Rules In Canada

Bennett Jones LLP
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On March 26, 2026, Canada's new transfer pricing rules received royal assent and will have a significant impact on multi-national enterprises (MNEs) in life sciences industries.

CanadaTax
Jehad Haymour
Jehad Haymour
Julia Qian Wang
Julia Qian Wang
Anna Lekach
Anna Lekach
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On March 26, 2026, Canada's new transfer pricing rules received royal assent and will have a significant impact on multi-national enterprises (MNEs) in life sciences industries. The rules now focus on enumerated "economically relevant characteristics" which will affect how the Canada Revenue Agency scrutinizes cross-border transactions. For life sciences companies operating cross-border, proactive compliance and assessment of transfer pricing considerations is essential to ensure that the CRA does not inappropriately challenge the chosen transfer price of MNE intra-group transactions.

Key Takeaways

Life science companies that operate across borders should be aware of the following:

  • The rules can affect how an MNE carries on business and, possibly, its ability to carry on business in certain jurisdictions. MNEs must give proper attention to the relationship between two (or more) members of the MNE to avoid the MNE being subjected to the taxation of the same income in more than

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