29 November 2016 CTF Roundtable Q. 9, 2016-0669801C6 - BEPS Action Item 13 -- summary under Subsection 233.8(3)

CRA indicated that BEPS Action Item 13 had been dealt with by the introduction of proposed s. 233.8 (respecting country-by-country reporting), which does not include a requirement to produce a Local File or a Master File and has no direct relation to s. 247 (including the contemporaneous documentation requirement in s. 247(4)). CRA stated that Action 13 thus has not altered its criteria regarding whether a taxpayer has made reasonable efforts to determine and use arm’s length transfer pricing.