Canada’s New Advance Pricing Agreement Program Called Restrictive

Companies seeking advance agreements with tax authorities in Canada on their transfer pricing methods will face more restrictions than they’ve seen in the past, tax lawyers said.

The Canada Revenue Agency’s first update to its advance pricing agreement program in more than 20 years doesn’t relieve concerns practitioners have had for years about the program’s rigidity over who can apply, according to Amanda Heale, tax partner at Osler Hoskin and Harcourt LLP.

“The hope would be that there would be more access to APA rather than less,” Heale said in a statement about the update.

The agency released Information ...