Canada Transfer Pricing Reform to Trigger More Audits, Disputes

Canadian companies could see a higher tax bill in the coming years as the country’s tax authority looks to net more corporate revenues using beefed up transfer pricing rules, top tax lawyers said.

The proposed reforms, detailed in a consultation paper, would expand the Canada Revenue Agency’s power to adjust a transfer pricing transaction upwards, the lawyers said. The changes will also increase the case load for tribunals that resolve tax controversies, they said.

The proposed changes are Canada’s first major overhaul of transfer pricing rules since they were initially put into law in 1997. ...