Glossary
Contemporaneous Documentation
Contemporaneous documentation is the transfer pricing paperwork a corporation prepares by the time it files its tax return, setting out how prices were set for transactions with related parties and why those prices meet the arm's length principle. Having the documentation in place at filing, rather than reconstructed after the fact, is what can protect a corporation from a transfer pricing penalty if the CRA later reviews the pricing. Our transfer pricing in Canada primer covers what the documentation needs to show.
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