17 May 2012 Roundtable, 2012-0444131C6 - Policy Initiatives

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Policy Initiatives
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English
Document number
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2012-0444131C6
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Conference
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Main text

Principal Issues: Update on policy initiatives under consideration by International and Large Business Directorate's International Tax Division

Position: Comments provided.

International Fiscal Association (IFA) Conference
Canada Revenue Agency Roundtable
May 17, 2012

Policy Initiatives

Question

Can you give us an update on any policy initiatives being considered by the International Tax Division?

Response

The International Tax Division implemented a policy review committee in June 2011 in order to generate international tax policy. This committee is made up of the same members as the TPRC. As a result of the work of this committee, the International Tax Division will issue the following two memorandums shortly:

  • TPM-13, Referrals to the Transfer Pricing Review Committee, which replaces TPM-07 and provides guidelines for referrals to the TPRC regarding possible transfer pricing assessments under paragraphs 247(2)(b) and (d), and penalties under subsection 247(3) of the Income Tax Act;
  • TPM-14, 2010 Update of the OECD Transfer Pricing Guidelines, which is to provide an overview of the significant changes made in the 2010 version of the OECD and of the CRA's position regarding these changes.

Jackson MacGillivray
2012-044413
May 17-18, 2012