Canada’s transfer pricing landscape has changed. Significant legislative amendments are now in force for tax years beginning after November 4, 2025, reshaping how the CRA may evaluate and challenge cross-border transactions.
In this session, we’ll focus on what these changes mean in practice for taxpayers and in-house teams. We’ll highlight where the rules are shifting, where uncertainty remains and how to prepare for this new reality.
Topics:
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Impact on scope for CRA challenges to taxpayers’ transfer pricing arrangements, including recharacterization risks
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What may (and may not) carry forward from the current transfer pricing jurisprudence
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Key implications for documentation, audits and disputes
Join us for a forward-focused discussion of how to navigate the new transfer pricing regime.
Event Details
Wednesday, April 22, 2026
1 p.m. - 2 p.m. (ET)
Online
Mandatory Continuing Education
Ontario
This program contains up to 1 hour of Substantive content.
British Columbia
This program has been accredited for up to 1 CPD Credit Hour with The Law Society of British Columbia.
Quebec
Please note that pursuant to the amendments to the Règlement sur la formation continue obligatoire des avocats (Regulation respecting mandatory continuing education for lawyers – available in French only) of the Barreau du Québec, which came into force on April 1, 2019, the status of “recognized provider” and the mandatory “recognition” of activities have been abolished.
Blakes will continue to provide you with a confirmation of participation for your records. As stipulated in the above-mentioned regulation, members must preserve supporting documents attesting their completion of training activities for a period of seven years beginning on April 30 following the end of the reference period during which such activities were completed.
