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Canada: APA statistics for 2018

Canada: APA statistics for 2018

The Canada Revenue Agency (CRA) continued to focus on new advance pricing arrangement (APA) applications, according to its 2018 APA program report.

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According the 2018 APA report:

  • There were 19 pending APA applications in 2018 (that is, a pre-file meeting had occurred, but the taxpayer had not made an APA submission).
  • The CRA completed 25 APAs in 2018 (down from the 36 APA completions in 2017 but about average for the past several years).
  • The average time to close a bilateral or multilateral APA was 44 months, and the median time to close these cases was 41.9 months.
  • The CRA accepted 32 new APA applications in 2018 (the most it has accepted since 2013-2014, and double the 16 applications accepted in 2017).
  • The CRA continued to emphasize the early stages of the APA process, including the pre-filing and due diligence stages, in the hope of realizing increased efficiencies later in the APA process.

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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