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Canada’s new transfer pricing rules are in effect for tax years beginning after the 2025 federal budget (i.e., 2026 for calendar year taxpayers). It will be many years before the courts weigh in on the impact of the amendments, but the time for multinationals to ready themselves for CRA audit scrutiny is now. Below, we outline the key changes in the amendments and the practical steps that taxpayers can take today.

A discussion on the constant evolution of transfer pricing, which is leading leading to various interpretations by multinationals and the governing tax authorities.

On June 26, 2020, the Federal Court of Appeal dismissed the Minister of National Revenue's appeal of the Tax Court of Canada's decision that reversed ...

In January 2020, the OECD/G20 Inclusive Framework on BEPS, a group of 137 countries including Canada, endorsed a statement, which affirmed their commitment to build a global solution...

The government declared that Federal Budget 2021 ("Budget 2021") is about finishing the fight against COVID-19 and creating prosperity for Canadians in the decades to come.

On November 4, 2025, the federal government tabled Canada Strong: Budget 2025 (Budget 2025), the first federal budget tabled by Finance Minister François-Philippe Champagne...

A partnership is not considered to be a separate legal entity for the purposes of Canadian income tax.

In Bank of Nova Scotia v His Majesty the King, the FCA confirmed the Tax Court's decision that arrears interest could accrue until the date of a reassessment, even in situations where a subsequent loss carryback effectively offsets most of the reassessed tax liability.

Taxpayers can easily make mistakes navigating a transfer pricing dispute without strategically considering the choices of pursuing domestic avenues for relief or pursuing treaty-based avenues...

Contrary to what taxpayers often assume, the Tax Court of Canada ("TCC") does not have jurisdiction over a wide range of disputes with Canada Revenue Agency...

On May 31, 2019, as one of the main areas of focus of the ongoing work on the Base Erosion and Profit Shifting ("BEPS") project, Members of the OECD/G20 Inclusive Framework on BEPS ("Framework")

Budget 2019 is the last federal budget of the current Liberal government before the upcoming federal election in October 2019.

In 2022, the federal government released draft legislation to adopt many of the OECD's BEPS recommendations, including those related to interest deductibility, anti-hybrid measures and mandatory disclosure.

The Federal Court of Appeal (FCA) recently dismissed the Crown’s appeals in Canada Trustcoand Imperial Oil with respect to the application of the general anti-avoidance rule (GAAR) in the Canadian Income Tax Act.

On December 4th, 2009, The Tax Court of Canada (herein referred to as "TCC") ruled on one of Canada’s most significant cases to date regarding guarantee fees, the case of General Electric Capital Canada Inc. (herein referred to as "GEC").

It seems that every day now there is an article of some sort addressing aggressive tax structures, often utilizing offshore entities, and the ramifications of (implied) inappropriate, underlying transfer pricing policies.

On May 31, 2024, the Quebec Court of Appeal ("QCCA") unanimously dismissed the Agence du Revenu du Québec ("ARQ") appeal in ARQ v. Kone Inc. The QCCA confirmed that a cross-border financing arrangement.

This bulletin focuses on the tax implications related to employees traveling between the United States and Canada.