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Canada's 2025 Budget Proposes Major Transfer Pricing Changes

January 5, 2026

Examining proposed reforms and their implications under existing law

Prime Minister Mark Carney's federal Liberal government released its first budget, proposing the most significant amendments to Canada's modern transfer pricing rules in nearly 30 years. In this article for Tax Notes International, Michael Kandev critically reviews these proposals in light of existing law. He examines Canada's current transfer pricing guidelines and compares them with the changes proposed in the 2025 budget.

The full article, originally published by Tax Analysts, can be found at Tax Notes International or by downloading the PDF from our website. 

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