Canada: Intercompany management fees | KPMG | BE

Canada: Intercompany management fees

Canada: Intercompany management fees

Canada Revenue Agency issues guidance targeting intercompany management fees


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The CRA guidance consists of:

  • A transfer pricing memorandum (TPM-15) on intra-group services (i.e., management fees) that appears to reflect some aspects of the OECD's base erosion and profit shifting (BEPS) initiative, and that stresses the need for taxpayers to determine that their transfer pricing policies are consistent with their public documents
  • A second memorandum (TMP-16) on the role of multiple-year data in transfer pricing analyses, reminding Canadian taxpayers that they cannot solely rely on transfer pricing documentation prepared by their foreign parent companies to support a position with the CRA


Read a February 2015 report prepared by the KPMG member firm in Canada: CRA Gets Tough On Intercompany Management Fees

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