Update - Competent Authority Services Division

Advance pricing arrangement (APA) prefiling meeting

Question 1

How would a taxpayer interested in filing for an APA get a prefiling meeting?

Answer 1

A taxpayer interested in filing for an APA has to first send a request-information package to the director of the Competent Authority Services Division at the Canada Revenue Agency (CRA) to ask for an APA prefiling meeting. As much as possible, an APA request-information package should include all the information listed in Appendix I of the CRA's Information Circular 94-4R, International Transfer Pricing: Advance Pricing Arrangements (APAs). The Division will review the package and, if satisfied that it is complete, will contact the taxpayer with possible date(s) for a prefiling meeting.

Certification of residency

Question 2

I will receive payments from a non-resident payer. The payer sent me a form issued by a foreign government that has to be completed by the Canadian competent authority to certify that I am a resident of Canada. Do I send this form to the CRA's Competent Authority Services Division, and what information do I have to provide?

Answer 2

No. It is not necessary to send your request for certification of residency to the Competent Authority Services Division. The CRA processes these requests in its taxpayer services regional correspondence centres. Canada's treaty partners generally accept these certifications. You can get information about certification of residency and how to get a certificate of residency on the CRA website at Certificate of residency.

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