The Canada Revenue Agency (CRA) continued to focus on new advance pricing arrangement (APA) applications, according to its 2018 APA program report.
According the 2018 APA report:
The APA report also indicates that, as in previous years, the majority of the in-process APA cases involved the transfer of tangible property. However, cases involving intangible property increased to 29% of all cases in 2018 (up from 17% in 2017). Consistent with prior years, APAs involving the United States represented more than half of the APAs in process.
Read a July 2019 report [PDF 145 KB] prepared by the KPMG member firm in Canada
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