• Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 4/15/2014

Canada - Intersection of BEPS and possible transfer pricing changes 

April 15: Could multinational corporations in Canada be subject to enhanced transfer pricing documentation and country-by-country reporting?

The Organisation for Economic Co-operation and Development (OECD) included transfer pricing and country-by-country reporting as part of the OECD BEPS* Action plan. In its 2014 federal budget, the Canadian government announced a parallel consultation process on BEPS and set a consultation period for interested parties to provide input to the Department of Finance by 11 June 2014.

It is not yet clear how the Canadian tax authorities could implement these changes, although one possibility is that Canada would follow an approach similar to the one taken when the OECD released the 2010 version of the Transfer Pricing Guidelines—in that instance, the Canadian tax authorities responded in 2012 with updated guidance in a new Transfer Pricing Memorandum.

Read an April 2014 report [PDF 53 KB] prepared by the KPMG member firm in Canada: OECD Responds To Concerns on Country-by-Country Transfer Pricing Reporting

*BEPS = base erosion and profit shifting

Contact a tax professional with KPMG's Global Transfer Pricing Services.

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