Tax & Trade Blog

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SIMPLIFIED CANADIAN TRANSFER PRICING RULES

NEW RULES ADDRESS OLD PROBLEM: SMALLER BUSINESS DOCUMENTATION STANDARDS

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Canada’s transfer pricing rules were first introduced in 1997 and essentially require Canadian businesses transacting with related foreign parties – for example, buying, selling or licensing goods, services and intangibles within a multinational corporate group – to maintain written documentation explaining how their prices comply with internationally accepted arm’s length principles. The Canada Revenue Agency (“CRA”) has historically adopted the OECD Transfer Pricing Guidelines for that purpose.

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NEW SURTAXES ALSO AFFECT STEEL & ALUMINUM

CARNEY GOVERNMENT’S NEW SURTAXES AMEND PRIOR STEEL & ALUMINUM ORDER!

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As part of the Canadian Federal Government’s new round of retaliatory surtaxes that came into effect on September 8, 2026, consequential amendments were made to the United States Surtax Order (Steel and Aluminum 2025) (the “Steel/Aluminum Surtax”).

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PROVISIONAL DUTIES ON CHINESE PLYWOOD

CBSA ISSUES PRELIMINARY DETERMINATION ON PLYWOOD FROM CHINA

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On August 24, 2026, the Canada Border Services Agency (“CBSA”) released a notice of its preliminary determination of dumping and subsidizing in respect of decorative and other non-structural plywood originating in or exported from the People’s Republic of China (the “Subject Goods”).

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PRELIMINARY DETERMINATION: STEEL RACKS

CBSA IMPOSES PROVISIONAL DUTIES ON STEEL RACKS FROM CHINA

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On September 2, 2026, the Canada Border Services Agency (“CBSA”) released a notice of its preliminary determination of dumping and subsidizing in respect of steel racks originating in or exported from the People’s Republic of China (the “Subject Goods”). Provisional duties are now imposed on imports of the Subject Goods released from the CBSA on or after September 2, 2026.

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DANGERS OF SELF-ISSUED USMCA CERTIFICATES

IMPORTERS MAY SIGN OWN CERTIFICATES – BUT AT OWN PERIL!

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One of the significant changes introduced by the Canada-United States-Mexico Agreement ("USMCA"), relative to the former NAFTA regime, was the expansion of who may complete and execute a USMCA Certification of Origin. In particular, importers are now permitted to complete and sign their own Certifications of Origin, rather than relying solely on exporters or producers.