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Transfer Pricing in Canada refers to the pricing of transactions between associated enterprises, ensuring they are conducted at arm's length. This practice is crucial for preventing profit shifting and ensuring that Canada receives its fair share of tax revenue.
The Canada Revenue Agency (CRA) enforces transfer pricing rules under Section 247 of the Income Tax Act. Canadian law aligns with OECD Transfer Pricing Guidelines, requiring taxpayers to document their intercompany transactions to demonstrate adherence to the arm's length principle. Failure to comply can result in significant penalties, including reassessments and documentation penalties, particularly for transactions exceeding certain thresholds (e.g., C$1 million in adjusted intercompany Non-Arm's Length transactions).