The Advance Pricing Arrangement (APA) program of the Canada Revenue Agency (CRA) is administered through the CRA's Competent Authority Services Division (CASD) in Ottawa. The CRA offers the APA program to assist taxpayers who are seeking prospective certainty with respect to crossborder related-party transactions.
The CASD recently released its annual report on Canada's APA program covering the year ended December 31, 2018 (the report).
For 2018, the APA program reported fewer APA closures than the 10 -year high reported last year. Nonetheless, APA productivity remains at the upper bound of case closures reported from 2013 to 2017, and the CRA was able to maintain a reasonable level of inventory - reporting only a marginal increase in active cases despite a relatively high intake. In addition, the APA program again showed improvements in overall case completion times, with less time taken in the negotiation and postnegotiation phases of the APA process.
