Canada resolved 115 Mutual Agreement Procedure (MAP) program cases through negotiations with other countries during FY 2014/2015, slightly more than the annual tally of settled negotiable MAP cases in preceding periods, according to data released August 20 by the Canadian Revenue Agency (CRA). In the four preceding fiscal year periods, total settled negotiable MAP cases ranged from 95 to 114 cases.
The FY 2014/2015 settled cases mostly involved resolution of economic double taxation between associated enterprises — 99 completed cases fell into that category. Nine cases involved residency and permanent establishments.
Most of the settled transfer pricing cases used the transactional net margin method (TNMM). Of these TNMM cases, 40 used operating margin, seven used the Berry Ratio, and five used cost plus. The cost plus transfer pricing method was applied in 32 of the settled cases, 12 cases used comparable uncontrolled price, and four used a profit split.
The agency accepted 217 new negotiable MAP cases during FY 2014/2015.
The CRA also provided data on acceptance and completion of non-negotiable MAP cases, which are MAP cases that do not involve negotiations with foreign governments.
In FY 2014/2015 the CRA settled 18 cases involving pensions, 29 cases involving gains, five cases involving US S corporation and estate estate rollovers, and three other cases, for a total of 55 cases. This total is significantly lower than totals for the past three fiscal years, which ranged from 175–216 completed cases.
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