Global

Details

  • Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 6/27/2014

Canada - MAP program report for 2013-2014 

June 27: A report about the 2013-14 mutual agreement procedure (MAP) program shows that the Canada Revenue Agency is making gains in some areas towards reaching its targeted completion times, but that completion times for foreign-initiated adjustments were up 40% from last year.

The Canada Revenue Agency concluded 105 MAP cases in 2013-14 (down from 114 cases in 2012-13), a 9% decrease. The balance between Canadian and foreign-initiated adjustments improved, as the last five years featured a larger percentage of Canadian-initiated adjustments.

Transfer pricing methodology

According to the MAP report, the transactional net margin method continues to be the dominant transfer pricing methodology used to resolve transfer pricing cases (38 out of 105 cases), followed by cost-plus (20 cases) and comparable uncontrolled price (CUP) (11 cases).


The resale price method was used to resolve three cases in 2013-14.


Taxpayers with cross-border business or financial dealings may find the MAP report offers insights about trends in administration of the MAP program.


Read a June 2014 report prepared by the KPMG member firm in Canada: Canada's MAP Program - 2014 Report Card



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




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