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The Canada Border Services Agency has made some significant changes to its position on the treatment of downward price adjustments in value for duty calculations.

The proposal acknowledges that the digital economy has made it necessary to make significant changes in the traditional concept of permanent establishment based on physical presence.

Canada's transfer pricing rules, first introduced in 1997, have historically imposed disproportionate compliance costs on smaller businesses while primarily serving large multinational enterprises. New draft regulations released in July 2026 introduce a simplified documentation regime specifically designed to reduce transfer pricing complexities for smaller Canadian businesses, while maintaining the existing penalty framework.

Transfer pricing involves the determination of an arm’s length price that one member of a multinational firm should charge another for the sale of goods.

The inaugural TP Minds Canada conference was held on June 11-12, 2019 in Toronto, Canada.

Many firms and practitioners creating transfer-pricing documentation often attempt, as their primary goal, to avoid costly transfer pricing penalties. Subsection 247(3) of the Canadian Income Tax Act (the "Act") discusses the application of such a penalty.

The Canadian government has proposed significant technical amendments to the Income Tax Act's definition of "taxable Canadian property" (TCP), fundamentally altering how publicly traded partnership units are classified and expanding the look-through rules for determining TCP status. These changes, effective upon Royal Assent, will impact cross-border transactions and investment structures by broadening the scope of what constitutes TCP and reinstating historical rules for options and interests in property.

The Canada Revenue Agency (CRA) has been auditing Bayer Canada for its 2013 to 2015 taxation years since 2016.

In preparation for the implementation of the LNG income tax in British Columbia starting in 2017, the Government of British Columbia has now established a website to provide more detailed information...

In a recent case in the Tax Court of Canada, the Minister of National Revenue failed to support a reassessment of AgraCity Ltd. (the "Taxpayer") under the transfer pricing rules...

On December 10, 2009, the United States Tax Court rejected the position taken in an Internal Revenue Service (IRS) deficiency notice in the transfer pricing area in a decision that has been viewed as favourable to taxpayers

To what extent are a multinational enterprise's intra-group contracts respected for transfer pricing purposes?

On June 7, 2017, Canada signed the OECD's Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI)...

Le budget fédéral de 2025 (le « Budget 2025 ») comprend des propositions législatives visant à moderniser en profondeur les règles canadiennes sur les prix de transfert...

Transfer pricing has been a favorite Canada Border Services Agency (CBSA) enforcement target for some time now. Payments made by importers because of income tax transfer pricing requirements can trigger obligations and liabilities under Canadian customs laws.

The two most significant Canadian cross-border tax developments in 2018 relate to transfer pricing and tax treaties.

In January 2024, the Department of Finance released a consultation paper on a proposed patent box regime, aiming to tax income from certain intellectual properties (IP) at preferential rates lower than the current federal rate.

The Income Tax Act (Canada) (the "Tax Act") contains an extensive set of transfer pricing rules designed to ensure that cross-border transactions entered into between Canadian taxpayers and non-residents with which they do not deal at arm's length are priced on an "arm's length" basis.