The Canada Revenue Agency (CRA) has issued a memo on transfer pricing on applications for contemporaneous documentation of the auditor entitled “PTM-05R” on March 28, 2014 and it replaces preceding PTM on the same subject dated 13 October 2004. TMP-05R notices the necessities for contemporaneous documentation in Canada, as includes in subsection 247 (4) of the Income Tax Act. This gives clearer guidance on when and how auditors can send requests, and how to collect contemporaneous documentation to reveal crucial efforts for avoiding penalties.