In particular, Appendix A of the consultation paper outlines draft legislative measures, which include: The consultation paper poses a series of 23 questions requesting specific input from stakeholders. In addition, the consultation provides stakeholders with the opportunity to provide input on administrative matters connected to transfer pricing, such as documentation and penalty provisions and the possibility of adopting more modern or simplified approaches in specific situations.
The main proposal concerns possible amendments to the transfer pricing adjustment rule in section 247 of the Act. These potential changes are intended to provide greater clarity on the application of the arm’s length principle in Canada.
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