Transfer pricing documentation prepared for the requirements in other jurisdictions not acceptable
In most, if not all, cases transfer pricing documentation prepared for the requirements in other jurisdictions, including the U.S., will not meet the Canadian documentation requirements. Taxpayers need to have transfer pricing documentation in place to support their inter-company transfer prices and this documentation must adequately address the contributions of the parties, in particular the Canadian entity. Failure to provide transfer pricing documentation within 3 months of the CRA’s request, even by one day, will give rise to the 10% transfer pricing penalty.
Take Note
This document is not intended to create an attorney-client relationship. You should not act or rely on any information in this document
without first seeking legal advice. This material is intended for general information purposes only and does not constitute legal advice. If you
have any specific questions on any legal matter, you should consult a professional legal services provider.