At times like this, when health and safety are at the forefront of everyone's mind, tax planning, including transfer pricing, understandably, is generally put aside. However, in light of the potential economic downturn arising from the COVID-19 pandemic, it would be prudent for Canadian companies to consider transfer pricing matters at this time.
The Canada Revenue Agency (CRA) has increasingly requested oral interviews during audits, particularly in transfer pricing audits. In Minister of National Revenue v. Cameco Corporation, the CRA sought an order compelling employees of the Cameco group to attend oral interviews. The decision of the Federal Court of Appeal (FCA) will be welcomed by taxpayers as it holds that an auditor does not have the power to compel such interviews.
Transfer pricing has been a favorite Canada Border Services Agency (CBSA) enforcement target for some time now. Payments made by importers because of income tax transfer pricing requirements can trigger obligations and liabilities under Canadian customs laws.
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