The Organisation for Economic Co-operation and Development (OECD) released the Stage 2 peer review report of Canada on August 13, relating to the outcome of the peer monitoring of the implementation of the Base Erosion and Profit Shifting (BEPS) minimum standards under Action 14 on improving tax dispute resolution mechanisms. Stage 2 focuses on monitoring the follow-up of any recommendations resulting from Canada's Stage 1 peer review report. Canada requested that the OECD also provide feedback concerning its adoption of the Action 14 best practices, and therefore, in addition to the peer review report, the OECD has released an accompanying document addressing the implementation of best practices. Overall, the report concludes that Canada addressed most of the shortcomings identified in its Stage 1 peer review report. These shortcomings principally included issues with Canada's treaties related to time limits for Mutual Agreement Procedure (MAP) submission and settlement implementation, and the absence of time limits for making transfer pricing adjustments.

A Tax Alert prepared by Ernst & Young Canada, and attached below, provides additional details.

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Full text of this Tax Alert