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

 

 

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.