Transfer Pricing Publications

View this page in: Français

Tax Tracks Episode 60: Will your foreign-based transfer pricing documentation withstand CRA scrutiny?
In this episode of Tax Tracks, we examine what could happen when a Canadian company’s foreign parent prepares its transfer pricing documentation. To ensure this documentation withstands CRA scrutiny, it should be reviewed to ensure that it meets Canadian standards.

PKN Alert: OECD base erosion and profit shifting project – update on transfer pricing issues
This PKN Alert provides the highlights and our initial comments on the proceedings.

Tax Tracks Episode 43: Revisions to the OECD transfer pricing guidelines: Chapters 1-3
In this episode Elisabeth Finch talks about the revisions to the OECD transfer pricing guidelines including why they should pay attention to them, how they might be affected, and how they should respond.

Tax Tracks Episode 15: Pressure Points in the Transfer Pricing Audit Process
Trying to manage the transfer pricing audit and assessment process can be strenuous. PwC's Susan Merlo shares insights and experiences relating to this growing concern.

Tax Tracks Episode 12: Transfer Pricing Advance Pricing Arrangements (APAs) - an update
PwC’s Remi Gray discusses the advantages of Advance Pricing Arrangements and shares key considerations for tax directors.

Tax Tracks Episode 11: Pricing Intercompany Guarantee Fees: the GE Capital Case — an Analysis by PwC’s Jeff Rogers
Read this podcast transcript for guidance on how the GE Capital Canada Inc. case results will impact multinationals. Or visit to listen to the episode.

Canadian Competent Authority Update
This paper discusses recent activity undertaken by the Canadian Competent Authority to advance the handling of cases through improvements to its advance pricing arrangement program.