Canada - CRA endorses update of the OECD Transfer Pricing Guidelines

Tax Insights ()

The Canada Revenue Agency ("CRA") recently published TPM-14 (one in a series of Transfer Pricing Memoranda) on the 2010 update of the OECD Transfer Pricing Guidelines (the "Guidelines"). TPM-14 explains the CRA's position on the OECD's revisions to Chapters I to III of the Guidelines as well as its guidance on business restructurings (included in a new Chapter IX of the Guidelines), both issued by the OECD on July 22, 2010.