The Canada Revenue Agency (CRA) has issued an annual report regarding Mutual Agreement Procedure (MAP) Program that gives an outline of the MAP Program during April 1, 2013 to March 31, 2014. The CRA inspires taxpayers to focus on double taxation or taxation not in accordance with an income tax convention considering the MAP Program. Statistical information is also emphasized in this report to give some close issues addressed by the CRA and its treaty partners.
The CRA concluded a 9% decrease has occurred on MAP cases. The number of MAP cases was 114 during 2012-13 and it is 105 during 2013-14. In accordance with the MAP report, the transactional net margin method continues to be the principal transfer pricing methodology used to resolve 38 transfer pricing cases out of 105 cases, followed by cost-plus can solve 20 cases and comparable uncontrolled price (CUP) can resolve 11 cases. The resale price method was used to resolve 3 cases during 2013-14.
