Canada Revenue Agency Guidance on Intra-Group Services and the Role of Multiple-Year Data

The Canada Revenue Agency published important new guidance earlier this year concerning transfer pricing for services and data analysis that uses statistical tools. These are important aspects of Canadian transfer pricing analysis. The CRA’s comments on statistical analysis are particularly important in light of its long-standing outlook on this kind of analysis. More generally, the CRA’s comments provide more general insight into how the CRA may approach complex or “bundled” transfers the elements of which may be difficult to separate.