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ARTICLE · 28 NOVEMBER 2019

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

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In Parts I and II of this article, we provided an overview of transfer pricing developments and jurisprudence, respectively, in Canada since the start of the Organization for Economic Cooperation

CanadaTax
Jim Wilson
Jim Wilson
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This article was created with assistance from Nathan Jin Bao, a summer student at Gowling WLG.

In Parts I and II of this article,1 we provided an overview of transfer pricing developments and jurisprudence, respectively, in Canada since the start of the Organization for Economic Cooperation and Development's ("OECD") project on Base Erosion and Profit Shifting ("BEPS"). Part III of this article, the final segment, deals with self-initiated transfer pricing adjustments and, more particularly, what has changed in this area since 2012.

Self-Initiated Upward Transfer Pricing Adjustments

Where a Canadian corporation has determined that it has understated taxable income on its filed tax returns, due to an error in its transfer pricing analysis, either a voluntary disclosure ("VD") or an application for an Advance Pricing Arrangement ("APA") with a rollback2 to prior taxation years are generally the taxpayer's only options to correct the matter. The Canada Revenue

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