Transfer Pricing

The Canada Revenue Agency (CRA), the Internal Revenue Service (IRS) and similar tax authorities across the globe have increased the scrutiny on transfer pricing and are placing a greater emphasis on the examination of transfer pricing practices.

The CRA allows an organization three months from the date of a written request to produce complete transfer pricing documentation. Furthermore, that documentation must have been prepared or updated at each year-end. Significant monetary penalties can result in the absence or incompleteness of transfer pricing documentation. Those penalties and any interest accrued are not tax deductible in Canada. At BGD, our professionals work closely with you in devising a strategy that is right for you. We can help your organization with all of its transfer pricing needs, including:

Obtaining advance pricing agreements
Defense of transfer pricing audit by CRA or other tax authorities
Transfer pricing risk assessments
Preparing contemporaneous documentation
Review of current transfer pricing practices
Implementation of transfer pricing best practices