Transfer Pricing Review Committee

What we do

The Transfer Pricing Review Committee (TPRC) was established in 2004 to review all cases where a transfer pricing penalty may be applied.

Our mandate

The mandate of the TPRC is to promote compliance with Canada’s transfer pricing rules by ensuring fair and consistent application of two aspects of those rules: transfer pricing penalties under subsection 247(3); and the recharacterization rule in paragraphs 247(2)(b) and (d).


The Director of the CRA’s International Tax Division chairs the TPRC. Other members include the International Tax Division’s Chief Economist and Senior Technical Field Advisors as well as a representative from Legal Services. A senior representative from CRA’s Tax Avoidance Division and from the Department of Finance Canada are invited to attend when required. The taxpayers and the tax services office audit team do not attend the TPRC meetings.


TPRC Summary – As of December 31, 2020

247(3) Penalty Referrals
247(3) Penalty Referrals Number of cases Percent of total
Penalty recommended 342 42.2%
Penalty not recommended 468 57.8%
Total 247(3) cases referred 810 100.0%
247(2)(b) Re-characterizations
247(2)(b) Re-characterizations Number of cases Percent of total
Denied 59 40.4%
Assessed 36 24.7%
Ongoing cases 51 34.9%
Total 247(2)(b) re-characterizations referred 146 100.0%

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