![]() ![]() Provision of safe‑harbour interest rates or ranges.Introduction of de minimis transaction rules and exemptions for small taxpayers.Other administrative measures considered in the consultation paper for which input is requested include the following potentially significant developments: ![]() Inclusion of a “consistency” provision referencing the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.Replacement of the current “recharacterization” provision in paragraphs 247(2)(b) and (d) of the Act with an explicit “non‑recognition” test.Increased emphasis on the “conditions” of the delineated transaction or series to allow adjustment where the conditions are different from those that would have been included if the participants had been dealing with each other in comparable circumstances.Introduction of the phrase “comparable circumstances” to limit the hypothetical comparison for the delineated transaction versus what anytwo (or more) persons dealing at arm’s length would have agreed to. ![]()
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