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, we assist organizations with all their 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

Let BGD help you. We will work closely with you in devising a strategy that is right for you.


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