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 Transfer Pricing Review Committee promotes 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).
Membership
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.
Statistics
TPRC Summary – As of November 26, 2025
| 247(3) Penalty Referrals | Number of cases | Percent of total |
|---|---|---|
| Penalty recommended | 541 | 48% |
| Penalty not recommended | 580 | 52% |
| Total 247(3) cases referred | 1,121 | 100.0% |
| 247(2)(b) Re-characterizations | Number of cases | Percent of total |
|---|---|---|
| Denied | 71 | 25% |
| Assessed | 95 | 33% |
| Ongoing cases | 121 | 42% |
| Total 247(2)(b) re-characterizations referred | 287 | 100.0% |