Canada: Consultation on proposed transfer pricing rules

Finance accepting comments until 28 July 2023

Finance accepting comments until 28 July 2023

The Department of Finance has released a consultation paper and accompanying legislative proposals that include changes to the Canadian transfer pricing rules, including amendments to the transfer pricing adjustment rule and possible revisions to certain administrative practices.

The consultation paper, which includes a series of questions for public comment, notes that these proposals are intended to provide more clarity on technical aspects of the application of the arm's length principle, and to better align the Canadian transfer pricing rules with international standards and transfer pricing guidance published by the Organisation for Economic Cooperation and Development (OECD).

Finance is accepting comments on these proposed changes until 28 July 2023. Although it is not yet clear when these proposed measures could be enacted, Finance notes that they are expected to apply on a prospective basis.

Read a June 2023 report [PDF 203 KB] prepared by the KPMG member firm in Canada



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