CRA lifts the lid on Transfer Pricing Review Committee
May 26, 2010
Jennifer Ryan, director of the international tax division at Canada Revenue Agency admits there is “no fairness” in transfer pricing documentation penalties.
The Transfer Pricing Review Committee (TPRC) was formed in 2002 to assess all transfer pricing adjustments that crossed a threshold of C$5 million or 10% of the company’s gross revenue. Since then, the committee has seen 262 cases. Around 53% resulted in penalties for the taxpayer, which equates to 10% of the reassessment.
Sorry. You must be a subscriber to view this article. Alternatively, why not take a free trial? To subscribe and access this article immediately simply click here or call +44(0)207 779 8380.