Transfer Pricing

This advanced module provides Canadian CPA professionals with a comprehensive understanding of Canada’s transfer pricing regime under Section 247 of the Income Tax Act, guided by the OECD Transfer Pricing Guidelines and Canadian administrative policy. Participants will explore the legal foundations of the arm’s length principle, key concepts such as functional and comparability analysis, and the application of both traditional and transactional profit-based methods. The course dives into documentation and penalty provisions, including contemporaneous documentation requirements and Form T106 filing obligations, as well as CRA audit practices and dispute resolution mechanisms. High-risk transactions—such as intercompany financing, IP licensing, and management fees—are dissected to highlight exposure under audit. The module also equips professionals with strategies for risk mitigation, such as intercompany agreements, Advance Pricing Arrangements (APAs), and alignment with the OECD’s BEPS initiatives including Country-by-Country Reporting. By the end of this module, learners will be able to develop compliant and defensible transfer pricing policies, recognize aggressive CRA enforcement triggers, and integrate transfer pricing planning within broader international and corporate tax strategies for clients with cross-border operations.