Saturday, 21 February 2015

Canada: CRA releases guidance on intra-group services

On February 13, 2015, the Canada Revenue Agency (CRA) released Transfer Pricing Memorandum (TPM)-15, Intra-group services and section 247 of the Income Tax Act.
TPM-15 clarifies the CRA's audit policy on several audit and tax issues commonly encountered during an international audit of intra-group services. It expands on guidance provided by the CRA in its Information Circular (IC) 87-2R, International Transfer Pricing, which was published in 1999. This new guidance has been in the works for many years and the timing of its release is interesting.
Source & more info: PwC