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.

Prepared by: Leonard Gilbert , Chris Marta

Leonard graduated from the University of Toronto, Faculty of Law (J.D. 2015) and is currently an associate practicing in the firm’s Toronto office. He previously performed extensively as a concert pianist and attended the Jacobs School of Music at Indiana… more »

Chris Marta is an associate practising in the firm’s Vancouver office. Chris Marta’s practice focuses on domestic and international tax planning for individuals, trusts and corporations. He also represents taxpayers in their disputes with the Canada Revenue Agency. Prior to… more »

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