Canada: Proposed simplified transfer pricing documentation requirements for small taxpayers and partnerships
Comments are due by September 4, 2026.
The Department of Finance on July 23, 2026, released draft legislation proposing simplified transfer pricing documentation requirements for small taxpayers and partnerships (and for a set of qualifying transactions, including small transfers of tangible property, small intra-group services transactions, and certain loans)—effective for tax years beginning on or after January 1, 2026.
The proposed simplified documentation requirements are intended to provide a reduced compliance alternative to the full Canadian transfer pricing contemporaneous documentation requirements for certain low-risk taxpayers and transactions. However, the proposal would include a related anti-avoidance rule.
Comments on the proposed changes are due by September 4, 2026.
Read a July 2026 report prepared by the KPMG member firm in Canada