Streamlined Documentation Requirements & Filing Deadlines

Canadian taxpayers engaging in cross-border dealings with affiliated non-residents must now prepare contemporaneous documentation that strictly follows ITA s.247(4). For fiscal years ending after December 31, 2024, documentation must be completed by the tax return due date (usually within six months after year end). The requirements are enhanced in line with the OECD Master File and Local File standards.

Source:

CRA Transfer Pricing Memorandum TPM-05R