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ARTICLE · 05 AUGUST 2019

Transfer Pricing: What's New In Canada (Part I)

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Since 2012, there have been unprecedented developments in Canada and globally in the area of international tax. The sheer volume and complexity

CanadaTax
Jim Wilson
Jim Wilson
Nathan Jin Bao
Nathan Jin Bao
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Since 2012, there have been unprecedented developments in Canada and globally in the area of international tax. The sheer volume and complexity of these developments make it difficult for Canadian corporations to keep up on what changes actually impact transfer pricing. Also during this period, in addition to some developments in the area of self-initiated transfer pricing adjustments, Canada generated several high profile court cases related to transfer pricing. This article, which will be released in three parts, provides an update on what is new in the Canadian transfer pricing landscape since 2012 when the Organisation for Economic Co-operation and Development ("OECD") began its Base Erosion and Profit Shifting ("BEPS") project. Part I provides a general overview of the transfer pricing developments in Canada during this period. Parts II and III, which will follow, will provide a brief summary of Canadian transfer pricing cases during this period and recent

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