Tax & Trade Blog

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SANCTIONS “DEEMED OWNERSHIP”

UNDER CANADA’S NEW RULES, NAME SCREENING ALONE NOW OBSOLETE?

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For years, many people have attempted to comply with Canada's sanctions rules by simply "name screening". New guidance from Global Affairs Canada ("GAC") may have made that approach obsolete, refocusing compliance on "deemed ownership", including aggregated ownership, board control rights and de facto control (e.g., through contracts and proxies).

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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。

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SIMPLIFIED CANADIAN TRANSFER PRICING RULES

NEW RULES ADDRESS OLD PROBLEM: SMALLER BUSINESS DOCUMENTATION STANDARDS

Download a PDF copy of this Blog here.

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.