On 6 June 2023, the Department of Finance Canada (Finance) released a consultation paper, ”Consultation on Reforming and Modernizing Canada's Transfer Pricing Rules,” to gather stakeholder input on various questions and proposals related to Canada’s transfer pricing legislation (the Consultation). The Consultation appears to be heavily influenced by perceived limitations in Canada’s transfer pricing rules as exposed by the Federal Court of Appeal’s decision in The Queen v. Cameco Corporation, 2020 FCA 112 (Cameco), and represents a potentially fundamental shift in the Canadian transfer pricing landscape.