Canada: APA Report and MAP Report 2014-2015

Available both in English and French, the Mutual Agreement Procedure (MAP) Report and Advance Pricing Arrangement (APA) Program Report were recently released by the Canada Revenue Agency.

These reports are available on DRTP resource page on Canada (English here; en français ici).

See also DRTP resource page on the USA here for US APA-MAP reports.

CRA MAP results for 2014-2015 are as follow:

“Of the 170 MAP cases that were resolved in fiscal year 2014-2015, 115 cases were categorized as negotiable, which means that bilateral negotiations with another tax administration were required to resolve an issue. Of the 115 cases negotiated with other tax administrations, 94% (109 cases) of taxpayers who sought assistance obtained full relief from double taxation, 3% (3 cases) obtained partial relief, and 3% (3 cases) did not obtain relief.”

“Non-negotiable cases are resolved by an agreement between Canada’s Competent Authority and specific taxpayers, and do not involve another tax administration.”

As we keep repeating, the number of double tax cases is indeed on the rise.

MAP Cases profile:

Fiscal Year Beginning Inventory Accepted Completed Ending Inventory
2014 – 2015 344 347 170 521
2013 – 2014 315 309 280 344
2012 – 2013 312 279 276 315
2011 – 2012 254 371 313 312
2010 – 2011 243 136 125 254


MAP cases are usually initiated by Canada, as seen below:

Fiscal Year Foreign – initiated Audit Adjustments Canadian – initiated Audit Adjustments Total
2014-2015 26 89 115
2013–2014 13 92 105
2012–2013 9 105 114
2011–2012 8 89 97
2010–2011 11 84 95


Robert Robillard, Ph.D., CPA, CGA, MBA, M.Sc. Econ.
Senior Partner, DRTP Consulting Inc.
514-742-8086; robertrobillard “at”

DRTP Consulting Inc. solutions go beyond transfer pricing and international tax solutions. The information in this blog post is general information only. Data and information come from sources believed to be reliable but complete accuracy cannot be guaranteed. DRTP Consulting Inc. or the author are not responsible or liable for any error, omission or inaccuracy in such information. The opinions expressed in this blogpost are those of the author. Readers should seek advice and counsel from DRTP Consulting Inc. as required.

Posted by drtp On 3 September 2015