As many treaties have limitation periods for making assessments, CRA considers it inadvisable to delay making a Part XII tax assessment arising from a transfer pricing adjustment (e.g.. a secondary adjustment arising under s. 214(3)(a)) until the transfer pricing issue has been resolved. However, a:
Part XIII collection policy has been adopted and applied by CRA in recognition of the OECD guidelines on Transfer Prcing by allowing MNE's to post acceptable security in lieu of the 100% payments required by the Income Tax Act.