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June 9, 2021

Canada Revenue Agency releases revised Information Circular on Mutual Agreement Procedures

The Canada Revenue Agency (CRA) released Information Circular IC71- 17R6 Competent Authority Assistance under Canada's Tax Conventions on June 1, replacing and cancelling Information Circular IC71-17R5, issued January 1, 2005. Among other items, the new Information Circular (IC) includes significant changes from the CRA's prior guidance or confirms its known positions on the following topics:

  • Mutual Agreement Procedure (MAP) filing procedures
  • Timing of Accelerated Competent Authority Procedure (ACAP) requests
  • Downward transfer pricing adjustment MAP requests
  • Collections procedures
  • Status of audit-level settlements

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


Full text of Tax Alert