[Verse 1]
When companies trade across the family tree
Section two-four-seven sets the rules you see
Arm's length principle guides the way
Price it like strangers would every day
Related parties cannot hide
From CRA's watchful eye inside
[Chorus]
Transfer pricing, keep it fair
Arm's length deals everywhere
Two-four-seven, OECD too
Document everything you do
A-P-A when paths unclear
Penalties when you don't adhere
[Verse 2]
OECD Guidelines light the path
Five methods help you do the math
Comparable uncontrolled price leads the way
Resale price method has its say
Cost plus markup, profit split
Transactional net margin fits
[Chorus]
Transfer pricing, keep it fair
Arm's length deals everywhere
Two-four-seven, OECD too
Document everything you do
A-P-A when paths unclear
Penalties when you don't adhere
[Verse 3]
Contemporaneous documentation's key
Records made when deals agree
Search and selection, rejection too
Explain the method chosen by you
Economic analysis must be sound
Before the transaction comes around
[Bridge]
When uncertainty fills the air
Advance Pricing Arrangements care
Negotiate with CRA
Set the rules before you pay
Bilateral or unilateral choice
Give your pricing strategy voice
[Chorus]
Transfer pricing, keep it fair
Arm's length deals everywhere
Two-four-seven, OECD too
Document everything you do
A-P-A when paths unclear
Penalties when you don't adhere
[Verse 4]
Twenty percent penalty awaits
When transfer pricing deviates
Primary adjustment changes your tax
Secondary deemed benefits stack
Gross negligence doubles the pain
Get it right the first time, don't refrain
[Outro]
From loans to royalties, goods and more
Transfer pricing rules explore
Keep it arm's length, document well
Let your pricing story tell
Canadian tax law stands so clear
Transfer pricing year by year