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from Transfer Pricing and Tax Controversy and Dispute Resolution
Canada’s APA program shows
August 14, 2019
The Advance Pricing Arrangement (APA) program of the Canada Revenue Agency (CRA) is
administered through the CRA’s Competent Authority Services Division (CASD) in Ottawa. The CRA
offers the APA program to assist taxpayers who are seeking prospective certainty with respect to cross-
border related-party transactions.
The CASD recently released its annual report on Canada’s APA program covering the year ended
December 31, 2018 (the report).
For 2018, the APA program reported fewer APA closures than the 10-year high reported last year.
Nonetheless, APA productivity remains at the upper bound of case closures reported from 2013 to 2017,
and the CRA was able to maintain a reasonable level of inventory — reporting only a marginal increase
in active cases despite a relatively high intake. In addition, the APA program again showed
improvements in overall case completion times, with less time taken in the negotiation and post-
negotiation phases of the APA process.
Year Ending December 31
Active case inventory (opening balance)
(average time in months)
APA type: Canada’s APA program
continues to be heavily weighted to
representing nearly 91% of workload
in both the current year and since
Industry sectors: Over half (56%) of
the cases in process involve
companies in the following industry
sectors: petroleum (24%), automobile
and other transportation equipment
(16%), and health (16%). The
following four sectors each accounted