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Canada to Release New Guidance on APAs in September

May 19, 2022, 7:12 PM

Canada’s tax authority is preparing new guidance on advance pricing arrangements and will release the document for public comment in September, an official said Thursday.

The Canada Revenue Agency is working on an update of Information Circular 94-4R—International Transfer Pricing: Advance Pricing Arrangements—that will consolidate all existing guidance on APAs, Sudha Dukkipati, acting director of the agency’s competent authority services division, told a conference. The APA program allows the agency and companies to agree on prices for intercompany transactions between related corporate entities as if they were conducted at arm’s length.

  • The new guidance will cover taxpayer roles and ...