The 2026 edition of Introduction to International Tax in Canada reflects several changes and updates. Their impact will be felt in many areas, but if one area had to be singled out as the one in which the new rules will have the greatest effect, it would likely be transfer pricing. Some may emphasize the continuity of the guidance provided by the OECD. That continuity should not, however, obscure the significance of the changes. For many taxpayers, nothing will change. For highly profitable large multinational enterprises, however, transfer pricing risk could increase. The new rules are broad in scope, and their boundaries remain unclear. It will likely take several years for the courts to clarify their application. Accordingly, Chapter 23 contains two developments that warrant particular attention: the section entitled "Canadian Transfer Pricing Reform" and Case Study 2, which addresses Canadian documentation.
The authors are: Jean-Pierre Vidal, Julie Robson, Marie-Pierre Allard, Marwah Rizqy, Cindy Harvey, Raphaël Clément, Candace M. Marriott, Angelo Nikolakakis, Allison Christians, Jayme Yeung, Mathieu Gendron, Camille Rivard, Sophie Casgrain, Chantal Jacquier, Annick Provencher, Étienne Coutu, Nadia Rusak, Jonathan Charron, Judith Charbonneau Kaplan, Sara-Michelle Marcotte-Génier, Lyne Latulippe, Gabriella Sobodker, Marie Blanchard, Audrey Bessette, Delphine Latulippe, Laura Gheorghiu, Malya Amghar, Vincent Dionne, Vincent Langlois, Julie Michaud, Sébastien Rheault, Jing Yu Wang, Chantal Bélanger, Nicolas Benoît-Guay.
A French edition of this book is also available: Introduction à la fiscalité internationale, 15e edition
