The CRA issued a new Transfer Pricing Memo TPM-02R for Part XIII withholding tax, interest and penalties on transfer pricing adjustments.

The Supreme Court of Canada dismissed the transfer pricing appeal on recharacterization in the Queen vs Cameco Corporation.

MDW’s bulletins track Canada’s plan for digital taxes from an election promise in 2019 to a throne speech, Auditor General report, and mini-budget in 2020.

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 It has been archived and will not be updated.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.

Finance Canada proposed changes to the Income Tax Act including changes for transfer pricing adjustments that involve GAAR. Two examples deal with related party loans and interest.

The CRA updated its website for transfer pricing, making it easier to navigate with helpful links to the income tax act and other reference materials for complying with the transfer pricing rules in Canada.

The 2018 Federal Budget included International Tax Measures to enhance the CRA’s (i) access to information, (ii) audit, and (iii) reassessment of transactions between a Canadian taxpayer and its foreign affiliates.

The CRA will receive $1 billion to crack down on tax evasion and avoidance. The 2018 Federal Budget committed $90.6 million over five years, plus $524 million in the 2017 Budget and $444 million in the 2016 Budget.