Avoiding transfer pricing disputes — A look at advance pricing arrangement program

By André Bergeron, Pierre Alary and Dale Hill ( September 14, 2021, 12:48 PM EDT) -- In the first of two articles, we explore Canada’s advance pricing arrangement (APA) program. The APA is an arrangement between the Canada Revenue Agency (CRA) and the taxpayer that covers specific transactions between the taxpayer and related non-resident entities. The Competent Authority Services Division (CASD) of the CRA is responsible for administering and negotiating all APAs....