Transfer Pricing Rules

Canada

Section 247 of the Income Tax Act defines the transfer pricing rules in Canada for transfer pricing adjustments, penalties, documentation, etc.

IC 87-2R: International Transfer Pricing provides guidance on the application of the transfer pricing rules.

The Transfer Pricing Memoranda series provides further guidance and examples on specific issues.

Further details are available on the Canada Revenue Agency web-site.

United States

Section 482 of the Internal Revenue Code defines the rules for applying transfer pricing in the U.S.

Section 6662 of the Internal Revenue Code defines the transfer pricing penalties and documentation requirements in the U.S.

Further details are available on the Internal Revenue Service web-site.

Other Countries

The Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations published by the Organization of Economic Cooperation and Development (OECD Guidelines) is the international standard used by most tax authorities around the world. However, Canada, the U.S. and other countries have interpreted the OECD Guidelines somewhat differently, and these differences are important.

Further details are available on the OECD web-site.