Consultation on Reforming and Modernizing Canada's Transfer Pricing Rules
Current status: Closed
The government carried out this consultation in order to gather stakeholder input on a range of questions and proposals related to Canada's transfer pricing legislation.
This engagement process gave taxpayers, tax practitioners, civil society groups, academics, and members of the public the opportunity to provide input on this topic. The consultation ran from June 6, 2023, to July 28, 2023. Thank you to everyone who participated.
Key questions for consideration
This consultation sought feedback on:
- possible amendments to the transfer pricing adjustment rule in section 247 of the Income Tax Act to provide greater clarity on the application of the arm's length principle in Canada in line with international consensus;
- administrative matters connected to transfer pricing, including documentation and penalty provisions and the possibility of adopting more modern or simplified approaches in specific situations; and
- any additional comments or feedback relevant to matters within the scope of this consultation.
Comments received during the consultation period will inform the government’s ongoing work to update the transfer pricing rules.
While this formal consultation has now concluded, Canadians are welcome to share their ideas and comments with the Department of Finance at any time.
- Announcement in Budget 2021 of the government's intention to consult on Canada's transfer pricing rules: Archived - Part 4 - Fair and Responsible Government | Budget 2021 (canada.ca)
- Transfer pricing consultation: Transfer Pricing Consultation - Canada.ca
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