The Canada Revenue Agency (CRA) has published new Transfer Pricing Memorandum (TPM-16) on 23rd February 2015 that reconfirms the CRA’s existing positions and gives proper instruction on the use of multiple-year data in determining an arm’s-length price. Taxpayers may require to give extra attention and effort to certify that their transfer pricing policies and documentation take this guidance into account. The CRA has released TPM-16, which organizes guidance on multiple year data. This memorandum refers to OECD Guidelines for Multinational Enterprises and Tax Administrations, published in 2010.
Related Posts

Canada: PBO projects CAD 4.5 billion revenue from proposed high-income tax brackets
Canada’s Parliamentary Budget Office (PBO) released its fiscal analysis of Motion M-24 on 24 September 2026,
Read More
US: Trump Administration shows no urgency on Canada trade deal as tariffs escalate
The Trump administration remains comfortable maintaining its trade standoff with Canada despite mounting economic
Read More
Canada extends federal fuel tax relief through March 2027
Canada’s Department of Finance has introduced Bill C-38, the Canadian Fuel Affordability Act, on 22 September 2026,
Read More
Canada: Supreme Court rejects Husky Energy bid to challenge dividend tax ruling
The Supreme Court of Canada has dismissed Husky Energy Inc.'s application for leave to appeal on 3 September 2026. The
Read More
Canada expands tax breaks with permanent Productivity Mega Deduction to attract global investment
Canada’s Prime Minister Mark Carney announced a new tax measure on 15 August 2026 aimed at strengthening Canada's
Read More
Canada introduces priority tax rulings for investments of CAD 1 billion or more
Canada’s Finance Minister François-Philippe Champagne announced on 14 September 2026 that the Canada Revenue Agency
Read More