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  • Transfer Pricing Update Canada ( May 2006 )
    Thomas B. Akin of McCarthy Tetrault

    During the past year, the Canada Revenue Agency ("CRA") has made transfer pricing a priority issue in its audits and has encouraged applications for bilateral Advance Pricing Agreements ("APAs"). The CRA also released a new transfer pricing memorandum dealing with requests for contemporaneous documentation and is implementing programs aimed at improving the quality of transfer pricing documentation prepared by CRA auditors.
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