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Continued Alignment with OECD Guidelines

January 1, 2025
Continued Alignment with OECD Guidelines

Continued Alignment with OECD Guidelines

Canada applies the arm's length principle to all cross-border transactions, as outlined in sections 247(2)--(4) of the Income Tax Act (ITA). Recent enforcement closely follows the OECD 2022 Transfer Pricing Guidelines for Multinational Enterprises, especially on method choice, comparability, and documentation.

Source:

OECD Transfer Pricing Guidelines 2022

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