Executive summary
On 22 February 2024, the Canada Revenue Agency (CRA) released Information Circular IC94-4R2, International Transfer Pricing: Advance Pricing Arrangements (APAs), which cancels and replaces Information Circular 94-4R, issued on 16 March 2001, and Information Circular 94-4RSR (Special Release), issued on 18 March 2005.
Among other items, the new Information Circular updates the CRA's guidance on the acceptance and processing of APAs, including guidance on the following topics:
- Prefi…