Canada: APA statistics for 2020

Information about the advance pricing arrangement (APA) program for 2020

Information about the advance pricing arrangement program for 2020

The Canada Revenue Agency (CRA) released a report containing information about its advance pricing arrangement (APA) program for 2020.

The APA program is intended to assist taxpayers by providing increased certainty on certain transfer pricing issues to prevent future transfer pricing disputes.

According to the release, the CRA accepted and completed more APA cases in 2020 compared to the previous year.

  • The CRA reported it accepted 19 new APA applicants in 2020 (up from seven in 2019).
  • The CRA also completed 15 cases (up from 12 in 2019).
  • The CRA reported it took an average of 36.9 months to complete bilateral and multilateral APA cases (down significantly from 51.1 months in 2019).
  • The majority of cases continued to involve the transfer of tangible property, accounting for 42% of APAs in process at the end of 2020.

The CRA indicated that it is currently engaged in bilateral or multilateral APA processes involving taxpayers from 18 different jurisdictions (Australia, Belgium, Chile, China, France, Germany, India, Ireland, Japan, Korea, Mexico, the Netherlands, New Zealand, Singapore, Sweden, Switzerland, the United Kingdom, and the United States). The APA report also confirms that the CRA will follow the OECD’s guidance for best practices regarding COVID-19-related issues for APAs, published in December 2020.

Read a May 2021 report [PDF 269 KB] prepared by the KPMG member firm in Canada



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