Skip to main content

Canada Issues Circular on Administrative Changes to Transfer Pricing

26th July 2021

Our final tax-news story takes us to the Great White North. Canada has released Circular 71-17R6 “Competent Authority Assistance under Canada’s Tax Conventions” to address administrative changes, which apply to a multitude of topics, including transfer pricing. As per the circular, the CRA will accept a Canadian taxpayer’s downward transfer pricing adjustment request if the following conditions are met: the request is completed within the treaty’s specified timeframe, the applicable tax authority has signed off on an upward adjustment, and the foreign competent authority has demonstrated efforts to resolve the case. The circular also says that MAP settlements should plan to be resolved within two years, assuming that the required information has been obtained.