Revised Advance Pricing Arrangements (APAs) Information Circular 94-4R now available

Ottawa, March 16, 2001... The Canada Revenue Agency (CRA) has published revised Information Circular 94-4R, which explains how to apply for and obtain an Advance Pricing Arrangement (APA) for Canadian income tax purposes.

APAs confirm, in advance, appropriate transfer pricing methodologies and their application to specific cross-border transactions or arrangements between entities that are not operating at arm's length. This provides certainty about the tax treatment of these transactions or arrangements.

The revised information circular incorporates many of the comments the CRA received from taxpayers, tax executives, and tax specialists during extensive consultations on the APA program service during the past year. The changes are designed to make the APA process more timely, less costly, and more attractive to businesses.

Information Circular 94-4R is available on the Internet. You can order printed copies by calling 1-800-959-2221 or any tax services office.

To request an APA or to make an appointment to discuss issues in more detail, telephone (613) 957-8859, send an email to ITD-APA@cra.gc.ca, or write to:

Director General
International Tax Directorate
Canada Revenue Agency
Ottawa, Ontario K1A 0L5
CANADA

Attention: Director, Competent Authority Services Division