Respecting the pandemic effect on various CRA international programs, CRA indicated:
- APA and MAP program operations have gradually resumed, and CRA is in contact with its treaty partners using virtual tools such as teleconferencing and, where possible, video-conferencing. Some MAP cases were recently closed using teleconferencing and with no travel. Members of the Transfer-Pricing Review Committee have been meeting using virtual tools such as teleconferencing with secure phone lines.
- There have been no discussions with our treaty partners to extend treaty time limits. Those are still applicable, and Bill C-20 (the Time Limits and Other Periods Act) does not apply to treaties.
- If a Treaty has no time-limits itself, then the usual domestic limits apply, for example, under s. 152 – again, subject to any changes provided in Bill C-20, that extend those delays for periods up to six months, but no later than December 31, 2020.