ARTICLE · 18 NOVEMBER 2025

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Understanding CRA Form T106 And How It Compares To U.S. Reporting Requirements

Rotfleisch & Samulovitch P.C.

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Canadian taxpayers who engage in cross-border dealings with related non-residents face special reporting requirements. One of the most important filings in this area is CRA Form T106, Information Return of Non-Arm's Length Transactions with Non-Residents.

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David Rotfleisch

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What Is CRA Form T106?

Canadian taxpayers who engage in cross-border dealings with related non-residents face special reporting requirements. One of the most important filings in this area is CRA Form T106, Information Return of Non-Arm's Length Transactions with Non-Residents.

The T106 form ensures that the Canada Revenue Agency (CRA) receives detailed information about transactions between Canadian residents and non-arm's length non-residents, including foreign affiliates, related corporations, family members abroad, or other non-residents with a special relationship.

The form is not a tax return—it does not determine taxes payable. Instead, it allows the CRA to assess whether Canadian taxpayers are correctly reporting income and whether transactions comply with Canada's transfer pricing rules under section 247 of the Income Tax Act.

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