Tax Insights ()
On March 28, 2014, the Canada Revenue Agency (CRA) published TPM-05R, a transfer pricing memorandum addressing auditor requests for contemporaneous documentation. This document cancels and replaces a previous TPM on this topic dated October 13, 2004.
TPM-05R pertains to the contemporaneous documentation requirements in Canada as stated in subsection 247(4) of the Income Tax Act (ITA). It introduces clearer guidance on when and how auditors can issue requests and how to gather contemporaneous documentation to demonstrate reasonable efforts for penalty protection.