CRA Transfer Pricing Audit — Montreal CPA Firm Near You: OECD-Aligned Defense Files

A CRA Transfer Pricing Audit targets intercompany transactions between related parties—whether within Canada or across borders—to ensure that all prices, royalties, and management fees reflect arm’s-length standards. For multinational enterprises and even small corporations with cross-border dealings, this is one of the most complex and high-stakes audits. Mackisen CPA Montreal specializes in preparing OECD-compliant documentation and defending transfer-pricing policies that stand up to CRA and Revenu Québec scrutiny.

Legal Foundation

Law: Income Tax Act s.247 — requires that related-party transactions be priced as if the parties were dealing at arm’s length.
Jurisprudence: GlaxoSmithKline Inc. v. Canada (2012 SCC) — establishes that transfer-pricing analysis must consider economic substance and the business reality of related-party transactions.

Why You Need a CPA for a Transfer Pricing Audit

CRA’s Transfer Pricing Division applies both OECD guidelines and Canada’s domestic tax rules. Auditors analyze intercompany pricing models, management fees, loan interest rates, royalties, and cost-sharing arrangements. A small error in comparables or methodology can result in massive reassessments, penalties of up to 10%, and even double taxation when another country disputes the adjustment.

Mackisen CPA Montreal ensures your documentation demonstrates commercial rationale, arm’s-length comparability, and tax fairness, protecting both your Canadian and global interests.

Learning insight: CRA doesn’t penalize fair pricing—it penalizes undocumented or poorly supported pricing. The quality of your documentation is your first line of defense.

What Mackisen CPA’s Transfer Pricing Audit Defense Includes

• Preparation and review of OECD-standard Master File and Local File documentation.

• Functional analysis to identify the roles, risks, and assets of each related entity.

• Economic benchmarking using independent databases and financial comparables.

• Documentation of intercompany agreements, invoices, and management reports.

• Representation in CRA transfer-pricing discussions and Competent Authority negotiations.

Learning insight: Transfer pricing is not about “cheap” or “expensive.” It’s about demonstrating commercial logic. A CPA builds the bridge between your numbers and your narrative.

Common Triggers for CRA Transfer Pricing Audits

• Large intercompany transactions without written agreements.

• Interest-free or low-interest loans between affiliates.

• Royalties or management fees that exceed market benchmarks.

• Discrepancies between Canadian and foreign tax filings.

• Absence of contemporaneous transfer-pricing documentation.

Mackisen CPA Montreal proactively detects these triggers and prepares documentation that meets both CRA and OECD standards before an audit begins.

How Mackisen CPA Manages the Process

1. Conducts a full functional and risk analysis across all related entities.

2. Benchmarks pricing and margin ratios against third-party comparables.

3. Documents arm’s-length principles with financial, legal, and operational evidence.

4. Engages directly with CRA’s Transfer Pricing Review Division.

5. Prepares Competent Authority submissions to prevent double taxation.

Learning insight: CRA audits rely on economic evidence. When a CPA provides the same level of quantitative and qualitative proof, the discussion becomes a negotiation—not a confrontation.

Benefits of Professional Representation

• Eliminates risk of 10% transfer-pricing penalties under s.247(3).

• Reduces exposure to double taxation across jurisdictions.

• Enhances credibility with CRA’s Transfer Pricing Division.

• Establishes globally consistent pricing models for future years.

• Strengthens internal controls and governance documentation.

Learning insight: Transfer-pricing documentation is not only about compliance—it’s about protecting global cash flow and preventing tax disputes that can last years.

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Learning insight: OECD-aligned documentation is your international compliance passport. Mackisen CPA ensures it’s precise, defensible, and ready for any audit.

Real Client Success

• A manufacturing subsidiary avoided a $1.2M reassessment when Mackisen CPA proved its management fees reflected real operational support under OECD guidelines.

• A technology firm prevented double taxation by securing CRA Competent Authority relief following our detailed intercompany benchmarking study.

• A distributor successfully justified transfer prices to Revenu Québec after our team presented multi-year profitability analysis and industry comparables.

Why Mackisen CPA Montreal

Mackisen CPA’s corporate tax team combines legal, financial, and analytical expertise to defend clients in high-stakes transfer-pricing audits. With over 35 years of combined experience and bilingual mastery of CRA and OECD frameworks, we protect corporations from costly reassessments and international disputes.

Learning insight: CRA focuses on intent and evidence. Mackisen CPA ensures both are documented in a way that proves business logic, compliance, and global fairness.

Learning conclusion: Transfer-pricing audits test how well your business can justify its internal economics. Mackisen CPA Montreal transforms that challenge into an opportunity to prove transparency, strength, and global integrity.