Bapa Agreements

September 12, 2021

These guidelines may be amended at any time, in accordance with the consultations of all PATA members. It is proposed to include the following points in a taxable person`s BAPA application. However, the PATA member should refer a taxable person to national procedures to ensure that all necessary information is provided. If, in their commercial or financial relations, conditions different from those which would be achieved between independent undertakings are encountered or imposed between the two undertakings, all profits which, under those conditions, would have been paid to one of the undertakings, but which were not generated by those conditions, may be included in the profits of that undertaking and taxed accordingly. A BAPA is an agreement, arrangement or similar undertaking between two (2) competent authorities with respect to the prospective definition of an acceptable and appropriate transfer pricing method (TPM) applicable to a cross-border transaction between affiliated undertakings, under certain conditions, for the purposes of the applicable agreement. Mr. Jim Gauvreau Director Director Competent Authority Service Division International Tax Directorate Canada Customs and Revenue Agency 5th Floor, Canada Building 344 Slater St. Ottawa, Ontario Canada, K1A OL5. Correspondence or exchange of information within the framework of these guidelines shall be carried out at the addresses indicated in Appendix E. The definitions marked with an asterisk come from the 1995 report to the OECD Committee on Fiscal Affairs, “Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations”. Mr. Robert H.