Canada: APA statistics for 2016 | KPMG | GLOBAL

Canada: APA statistics for 2016

Canada: APA statistics for 2016

The Canada Revenue Agency (CRA) released an advance pricing arrangement (APA) program report for 2016.

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The results from the latest APA report indicate that the CRA is focused on a backlog of existing APAs. Other information from the APA report reveals:

  • The CRA began the 2016 calendar year with 107 active cases.
  • Year-end closing inventory was 90 cases, with the CRA accepting 12 new cases. 
  • The CRA is actively engaged in bilateral or unilateral APA processes with taxpayers from 15 different countries.
  • Cases involving transfers of intangible property make up over half of the APAs in process.
  • 90% of all current cases involve bilateral or multilateral requests; only 10% of taxpayers sought an APA on a unilateral basis.
  • The average time to conclude a bilateral APA under the program was just over 47 months.
  • The Transactional Net Margin Method continues to be the most popular method to establish transfer prices under an APA.
  • Approximately 56% of all APAs in process involve the United States.

 

Read a November 2017 report prepared by the KPMG member firm in Canada

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