CRA Update

Matthew Wall CRA Updates, Transfer Price

The CRA has cancelled the IC 87-2R on International Transfer Pricing. It has been archived and will not be updated. Further, TPM-03 on Downward Adjustments is under revision.

OECD – Financial Transactions

Matthew Wall OECD

The OECD issued a new chapter for pricing financial transactions – e.g., loans, cash pooling, hedging, guarantees, captive insurance, and rates of return.