Looking for Clarity on Canadian Audits: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re looking to Canada, where practitioners are raising concerns about the government applying a draft transfer pricing rule rewrite to corporate tax audits—even as the proposed law to make the change remains in limbo.

The Canadian government has been working to overhaul its transfer pricing rules for more than four years. The effort started after the Canada Revenue Agency lost a court battle over its transfer pricing audit of uranium miner Cameco Corp.

The ruling undermined the government’s ability to “recharacterize” intercompany transactions and raise tax ...