Consultation on reforming and modernizing domestic transfer pricing rules
Jun 06, 2023
On June 6, 2023, Canada's Department of Finance issued a much-anticipated consultation paper to gather stakeholder input on a range of questions and proposals related to Canada’s transfer pricing legislation. The deadline for stakeholders to provide their submissions is July 28, 2023.
The main legislative changes contained within the consultation paper concern amendments to the transfer pricing adjustment rule set out in section 247 of the Income Tax Act. These proposed amendments aim to align the transfer pricing adjustment rule in section 247 of the act with the guidance provided by the OECD in the latest version of its report on the general application of the arm’s length principle: Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
Review the consultation paper on the Canada’s Department of Finance Website.
