Organization: Canada Revenue Agency
Year: 2022
Month: September
Request Number: A-2022-149587
Request Summary: The statistics by fiscal year of the number of cases referred to the Transfer Pricing Review Committee (TRPC) and the number of cases on which a penalty was applied including the total dollar amount of transfer pricing penalties assessed each fiscal year, the statistics by fiscal year of the number of cases referred, and the total number of “hybrid debt” referral to the TPRC and the number where recharacterization was approved.
Disposition: All disclosed
Number of pages: 3