Tax & Trade Blog

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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

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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。

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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.