Canada's place in the contemporary transfer pricing world

This article looks at Canada's place in the contemporary transfer pricing world. After describing the international and Canadian contexts, the article examines various aspects of transfer pricing in Canada, such as the regulatory context, the legislative statement of the arm's length principle and the administrative rule, applying the arm's length principle, penalties and documentation, reassessments, access to information, and administration of transfer pricing. The article also considers two issues of contemporary interest in transfer pricing in Canada: attributing profits to permanent establishments and a broader review of transfer pricing and Canada's international tax rules.