Canada’s advance pricing arrangement program: Application and key considerations

By André Bergeron, Pierre Alary and Dale Hill ( September 24, 2021, 2:15 PM EDT) -- In part one of our series (see link below), we explored Canada’s advance pricing arrangement (APA) program, specifically looking at the interplay between years under audit and prospective years, and the types of APAs that can be negotiated between the Canada Revenue Agency (CRA) and the taxpayer. In this second part, we will review how the APA is applied and explore key considerations when looking at whether or not a taxpayer is a good candidate for the APA program....

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