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Form T106 is required as it discloses a corporations transfer pricing information to the Canada Revenue Agency (CRA). The CRA uses the information provided in the T106 to screen non-arms length transactions for review and audit. A corporation must complete a separate T106 for each non-resident.
The T106 Return must be filed when total transactions during a taxation year between a reporting person, which may be a corporation (including the Canadian branch of a nonresident that must report transactions with other non-arms length nonresidents), individual or trust, or a partnership, and all non-arms length
Subsection 162(7) (Failure to Comply) provides for a late-filing penalty up to $2,500 per late-filed T106 Slip.
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By contrast, a transaction would not be arms length if the buyer and seller are personally relatedsuch as family members or personal friends. Transactions between related businesses, such as those made between a parent company and its subsidiary, would also not be arms length.
The T106 Summary and Slips are annual information returns used to report non-arms length transactions between reporting persons or partnerships and non-residents under section 233.1 of the Income Tax Act (Act).

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