Notice, Information Circular 87-2R, Note of explanation

1. The attached is the final version of Information Circular 87-2R providing guidance with respect to the application of the transfer pricing rules set out in section 247 of the Income Tax Act which received Royal Assent on 18 June, 1998.

2. The Draft amendments to section 247 and the draft of this Information Circular were released for comments on September 11, 1997.

3. In the course of the review, it was noted that there was a discrepancy between the English and French wording in subsection 247(4) of the Act.

4. This final version of Information Circular 87-2R has been prepared using as definitive the English language version of subsection 247(4).

5. The Department of Finance has agreed that they would recommend amendments to the Income Tax Act, at the earliest opportunity, to make the French language version of subsection 247(4) consistent with the English language section, retroactive to the date that subsection 247(4) came into force.

6. We apologize for any inconvenience this may have caused.