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

A CRA Transfer Pricing Audit examines transactions between related Canadian and foreign entities to ensure that they comply with the arm’s-length principle established by the OECD and codified in Canadian law. CRA and Revenue Québec increasingly use data analytics, country-by-country reporting, and risk indicators to identify pricing irregularities, management fees, and intercompany loans that deviate from market norms. Mackisen CPA Montreal builds complete OECD-aligned transfer pricing documentation that protects your organization from penalties, double taxation, and lengthy reassessment disputes.

Legal Foundation

Law: Income Tax Act s.247; Tax Administration Act (Québec) s.19; OECD Transfer Pricing Guidelines 2022.
Jurisprudence: GlaxoSmithKline Inc. v. Canada (2012 SCC) — confirmed that transfer prices must fall within a reasonable range of market comparables, not a single exact value.

Why You Need a CPA for Transfer Pricing Audits

Transfer pricing audits are technical, data-intensive, and internationally coordinated. CRA’s Transfer Pricing Review Division and Revenue Québec’s Large Business Unit share global data to analyze your company’s financial ratios, profit allocation, and contractual terms. A CPA ensures your documentation not only meets compliance standards but also narrates your business model’s economic substance.

Mackisen CPA Montreal’s approach integrates tax law, accounting, and economic benchmarking to demonstrate that your intercompany prices align with fair market value (FMV) and commercial reality.

Learning insight: CRA tests numbers with context. A CPA translates your business logic into legally acceptable evidence.

What Mackisen CPA’s Transfer Pricing Defense Includes

• Preparation of Master File, Local File, and Country-by-Country Reporting (CbCR) documentation.

• Functional and comparability analyses for intercompany goods, services, loans, and IP.

• Benchmarking using OECD-approved databases to prove arm’s-length range compliance.

• Documentation of intra-group service charges, royalty rates, and cost-sharing arrangements.

• Legal memoranda citing OECD, CRA, and jurisprudence interpretations.

Learning insight: CRA and ARQ don’t challenge relationships—they challenge evidence. Transfer pricing documentation transforms relationships into compliance.

Common Triggers for CRA Transfer Pricing Audits

• Persistent low profit or loss in related-party transactions.

• Management fees or royalties with no supporting contracts.

• Loans or guarantees lacking interest-rate benchmarking.

• Inconsistent profit margins between related entities.

• Cross-border cost-sharing arrangements without clear allocation rules.

Mackisen CPA Montreal identifies these risk indicators and builds a proactive defense before CRA opens a file.

How Mackisen CPA Manages Transfer Pricing Audits

1. Reviews CRA and ARQ audit letters and identifies the specific related-party focus.

2. Collects intercompany agreements, invoices, and transfer-pricing reports.

3. Conducts independent benchmarking studies compliant with OECD standards.

4. Prepares CPA-certified documentation demonstrating commercial rationality.

5. Coordinates Advance Pricing Arrangements (APA) or Mutual Agreement Procedures (MAP) if required to prevent double taxation.

Learning insight: CRA’s challenge is global—but so is your defense. Documentation aligned with OECD standards speaks an international compliance language.

Benefits of Professional Representation

• Eliminates exposure to 10% transfer pricing penalties under ITA s.247(3).

• Reduces risk of double taxation in cross-border jurisdictions.

• Protects intercompany loans, IP valuations, and management-fee deductions.

• Strengthens corporate structure credibility in future tax filings.

• Builds a defensible audit trail for all global transactions.

Learning insight: Transfer pricing is not about avoiding tax—it’s about proving fairness. A CPA proves your fairness mathematically and legally.

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Learning insight: CRA measures fairness through comparability. Mackisen CPA ensures your numbers fit within the range that proves integrity, not just compliance.

Real Client Success

• A Canadian software company cleared a $2.3M transfer pricing adjustment after Mackisen CPA proved IP licensing aligned with OECD comparables.

• A manufacturing group avoided double taxation when our firm facilitated a bilateral MAP agreement with the U.S. IRS.

• A consulting network prevented a 10% CRA penalty by submitting contemporaneous documentation before audit notice.

Why Mackisen CPA Montreal

Mackisen CPA Montreal merges financial analysis with international tax law. Our multilingual audit defense team handles cross-border data exchange, ensuring every intercompany transaction meets both economic and legal scrutiny. We protect not just your numbers—but your global reputation.

Learning insight: Transfer pricing defines how your company tells its global story. Mackisen CPA ensures the story stands up to the world’s toughest tax authorities.

Learning conclusion: CRA’s transfer pricing audits test fairness, not fortune. Mackisen CPA Montreal ensures your global intercompany pricing is transparent, documented, and defensible—turning compliance into strategic confidence.