Transfer pricing risk assessments

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Protecting your organization's tax position

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:

  • Identification of potential problem areas
  • An assessment of compliance and documentation requirements
  • An action plan for remedial measures
  • A foundation for building your tax audit defense
  • A solid base for further planning and effective tax rate management

Contact a member of our Transfer Pricing practice to discuss your risk exposure concerns.