Tax & Trade Blog

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FCA OVERTURNS CITT IN MEDLINE

FCA RESTORES NARROW “FOR USE IN” TEST FOR CHAPTER 99 RELIEF

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Importers seeking duty relief under Chapter 99 of the Customs Tariff often need to establish that imported goods are “for use in” other qualifying goods or activities. In Canada (Attorney General) v. Medline Canada Corporation, 2026 FCA 74 (“Medline Canada”), the Federal Court of Appeal (“FCA”) clarified that this phrase requires more than goods being used together in a practical or commercial sense with limited or no physical connection — overturning a prior Canadian International Trade Tribunal ("CITT”) decision.

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TARIFF CLASSIFICATION & BILINGUAL INTERPRETATION

CITT CONFIRMS THE NARROWER SHARED MEANING MAY DETERMINE THE RESULT

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Tariff classification is the process of identifying and categorizing goods imported into Canada under the applicable tariff provisions. It determines the applicable rate of customs duty and, in turn, how much duty an importer must pay when the goods enter Canada.

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NEW US FOREIGN IMPORTER OF RECORD RULES

NEW RULES WILL AFFECT CANADIAN BUSINESSES IMPORTING INTO THE US

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Both Canada and the US have a concept that allows a foreign entity to act as the "importer of record" of goods into the other country – traditionally referred to in Canada as a “non-resident importer” or NRI. The US term for this is a “foreign importers of record” or FIOR.

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CANADA-CHINA TRADE RESET

SIX MONTHS LATER: WHAT HAS REALLY CHANGED?

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Following escalating trade tensions since 2024, Prime Minister Carney’s January 2026 visit to China produced a notable attempted “reset” in Canada-China trade relations. The tariff measures agreed to as part of that reset took effect on March 1, 2026.

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加拿大转让定价规则获简化

新规解决老问题 —— 中小企业的文档准备要求

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SIMPLIFIED CANADIAN TRANSFER PRICING RULES

NEW RULES ADDRESS OLD PROBLEM: SMALLER BUSINESS DOCUMENTATION STANDARDS

For the English Version of this Report, please click here.

加拿大的转让定价规则最早于1997年引入。该规则要求加拿大企业与境外关联方进行交易时——例如，在跨国企业集团内部购买、销售或许可使用货物、服务及无形资产——必须保存书面资料说明其定价方式符合国际公认的独立交易原则。加拿大税务局（CRA）历来采用经济合作与发展组织（OECD）的《转让定价指南》作为审查依据。