• Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 6/4/2014

Canada - New guidance concerning contemporaneous documentation 

June 4: Corporations that engage in cross-border transactions with a related party need to be aware of updated guidance from the Canada Revenue Agency (CRA) with respect to contemporaneous documentation.

The CRA’s updated Transfer Pricing Memorandum (TPM-05R), Requests for Contemporaneous Documentation, clarifies the CRA’s process for requesting contemporaneous documentation—including when the three-month response deadline applies and the manner in which taxpayers are expected to comply with this request.

The revised memorandum also reiterates that taxpayers must respond to all CRA requests for contemporaneous documentation.

The position of the CRA is that these changes will help correct some of the incorrect assumptions and avoidable mistakes that taxpayers make when preparing contemporaneous documentation.

Specifically, TPM-05R includes four new sections:

  • Method of delivery
  • Three-month deadline
  • Documents provided to the CRA
  • Reasonable efforts

Read a June 2014 report prepared by the KPMG member firm in Canada: Contemporaneous Documentation — New CRA Guidance

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

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