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transfer pricing Archives

The basics of the law, the guidelines, the circulars, the TPMs, and how they relate to Canadian transfer pricing

An understanding of the nature and significance Provisions of Canadian law, the OECD guidelines (Guidelines), and the administrative circulars and memoranda of the Canada Revenue Agency (CRA) as set forth in Circulars and Transfer Pricing Memorandums (TPM) is critical to understanding transfer pricing. All are all in a process of continual evolution. This memorandum is an explanation of the basics of each, and how they interact with each other.

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