The Canada Revenue Agency (CRA) has become more aggressive in re-characterizing certain activities involving transactions with offshore entities. If the tax authority decides that the terms of a transaction or a series of transactions do not meet the arm’s-length principle, a reassessment may be made that significantly affects the tax positions of the parties involved.
Organizations must face the possibility that the CRA could review and challenge their offshore structures and/or transactions. To evaluate their tax position, organizations should consider obtaining a high-level review of their structure, transactions and transfer pricing policies to confirm that transactions clearly maintain the arm’s length standard.
How PricewaterhouseCoopers can help
Our transfer pricing, international tax, and valuation professionals can provide a review of your transfer pricing position to assess your exposure and develop options for managing and mitigating this risk.
We can provide you with our Offshore Structures and Transactions Analysis, a high-level, cost-effective assessment that includes:
Contact a member of our Transfer Pricing practice to discuss your risk exposure concerns.