Canada’s APA Program

Published on October 20, 2011 – Bloomberg BNA

The Canada Revenue Agency has experienced “an unprecedented interest” in the Advance Pricing Arrangement (APA) program over the past several months, a Canadian official told BNA Tax Management Oct. 13.

Responding to criticism that new requirements for submitting APAs are preventing the CRA from accepting difficult cases, Lucie Bergevin, head of the CRA’s International and Large Business Directorate, noted current resource constraints at the Agency. She said the CRA “will continue to act responsibly by implementing operational efficiencies, wherever possible, and by balancing APA intake in accordance with existing budget realities.”

Bergevin also said issues such as business restructuring are better addressed through the CRA’s audit compliance  program. APAs, she said, “are best suited for recurring transactions that will continue into the future with little or no change.”

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