TPDoctor: Canada Revenue Agency disputes
June 10, 2009
The CRA has a reputation for being aggressive. What is the best way to avoid disputes? Or handle them if they arise?
The Canada Revenue Agency (CRA) has publically indicated that transfer pricing is one of its key areas of tax enforcement. The CRA employs over 400 dedicated transfer pricing auditors nationally and conducts in excess of 2000 transfer pricing audits annually. The CRA has indicated that it is seeking to have 100% coverage of large case taxpayers with respect to transfer pricing transactions. The CRA has also recently launched enforcement programmes such as the aggressive international tax planning initiative which includes review of certain transfer pricing transactions.
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