First Reference company logo

Inside Internal Controls

News and discussion on implementing risk management

machine cogs image

transfer pricing policy

Federal Court of Appeal holds Canada Revenue Agency does not have the power to compel oral interviews during audit

The Canada Revenue Agency (CRA) has increasingly requested oral interviews during audits, particularly in transfer pricing audits. In Minister of National Revenue v. Cameco Corporation, the CRA sought an order compelling employees of the Cameco group to attend oral interviews. The decision of the Federal Court of Appeal (FCA) will be welcomed by taxpayers as it holds that an auditor does not have the power to compel such interviews.

 

, , , , ,

New CBSA transfer pricing policy creates opportunities and obligations for importers

CBSA

Transfer pricing has been a favorite Canada Border Services Agency (CBSA) enforcement target for some time now. Payments made by importers because of income tax transfer pricing requirements can trigger obligations and liabilities under Canadian customs laws.

 

, , , , , , , , , , , ,