CRA Updates Guidance on Competent Authority Assistance
On June 1, 2021, the CRA published Information Circular IC71-17R6 (“IC71-17R6”), which provides guidance on obtaining assistance under a mutual agreement procedure (“MAP”) article of a Canadian tax convention. New IC71-17R6 replaces and cancels its predecessor IC71-17R5 dated January 1, 2005.
The new circular notably provides target deadlines for the MAP process, beginning from the date that “all necessary information required to work the case has been received”. Those targets are 6 months for finalizing and sending a position paper to the other competent authority, and 24 months for the completion of the entire MAP process.