With several Canadian miners embroiled in acrimonious standoffs with the Canadian Revenue Agency (CRA) regarding transfer pricing rules, mining companies will have to come to terms with increased levels of uncertainty in their tax profiles, and will need to consider the impact of all changes not only on existing structures, but also on new investments and transactions.
Since the CRA first introduced transfer pricing rules in 1998 to counteract base erosion and profit shifting (BEPS), more Canadian resource firms have been singled out for their purported aggressive tax planning and alleged tax evasion schemes.
