The Canada Revenue Agency (CRA) has issued Information Circular 94-4R2 International Transfer Pricing: Advance Pricing Arrangements (APAs), which is dated 22 February 2024. The information circular provides comprehensive guidance on APAs with a specific focus on establishing what is required from taxpayers to enter the APA program and the criteria used by the CRA in assessing whether taxpayers and transactions are suitable for an APA. The aim of the guidance is to provide increased transpare…