Canada: Transfer Pricing

Business leaders operating across borders frequently compare the Canada Revenue Agency (CRA) and the Internal Revenue Service (IRS) when evaluating tax compliance risk, administrative efficiency, and audit exposure.

Canada’s new transfer pricing rules are in effect for tax years beginning after the 2025 federal budget (i.e., 2026 for calendar year taxpayers). It will be many years before the courts weigh in on the impact of the amendments, but the time for multinationals to ready themselves for CRA audit scrutiny is now. Below, we outline the key changes in the amendments and the practical steps that taxpayers can take today.

On March 26, 2026, Canada's new transfer pricing rules received royal assent and will have a significant impact on multi-national enterprises (MNEs) in life sciences industries.

On March 6, 2026, the Tax Court of Canada (the Tax Court) issued a judgment (Judgment) in the matter of ExxonMobil Canada Resources Company v His Majesty the King, 2026 TCC 42 (the Tax Court Appeal)...

Over the past years the Government of Canada ("Government") has furthered tax reform by announcing legislative proposals and draft legislation and enacting technical amendments...

In an eventful start to 2026, the Federal Court of Appeal (FCA) has already released five notable tax decisions. Signalling an active and consequential year ahead...

In the 2025 Federal Budget, the Canadian government confirmed that it intends to proceed with measures with respect to non-compliance with information requests...

Canadian taxpayers who engage in cross-border dealings with related non-residents face special reporting requirements. One of the most important filings in this area is CRA Form T106, Information Return of Non-Arm's Length Transactions with Non-Residents.

On November 4, 2025, the federal government tabled Canada Strong: Budget 2025 (Budget 2025), the first federal budget tabled by Finance Minister François-Philippe Champagne...