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.
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