The Canadian Federal Court of Appeal has found in favour of the taxpayer in a case concerning access by the Canada Revenue Agency (CRA) to BP’s tax accrual working papers (TAWPs). The access issue arose as part of CRA’s scrutiny of BP’s uncertain tax positions. It is not yet clear whether CRA will appeal the decision.
The Court ruled that the CRA did not have “general and unrestricted access” to taxpayers’ identification of their uncertain tax positions.
CPA Canada, the professional accountancy institute, intervened in the litigation, arguing that routine access to TAWPs might discourage companies from preparing information relevant to the work of company auditors.
A detailed analysis of the case from PwC Law LLP can be accessed by clicking here.