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…