Initial Prior Year MITT
A taxpayer must submit the initial prior year MITT including transfer pricing studies pertaining to intellectual property and financing transactions along with any Global Tax Organization Chart (GTOC) updates within 90 days of the end of the prior tax year using information from that year. The timing for filing this MITT may necessitate the use of estimates and this should be noted on the form. This MITT will be used by the Transfer Pricing Risk Assessment (TPRA) Team to conduct the initial transfer pricing risk assessment for the current CAP year.
For example, the Initial 2020 MITT using information from the tax year ending December 31, 2020 is due March 31, 2021. This MITT will be used by the TPRA Team to conduct the initial transfer pricing risk assessment for the 2021 CAP year.
Interim Current Year MITT (if necessary)
An interim MITT is required within 30 days of the completion or occurrence of a new material transaction or a material change to an existing transaction listed on the most recent MITT submission.
For example, if on June 30, 2021 there is a material change to a transaction that was reported on the Initial 2020 MITT, the Interim MITT with that transaction is due on July 30, 2021. This MITT will be used to update the TPRA Team's prior risk assessment.
Final Prior Year MITT
A taxpayer must submit the final prior year MITT when the tax return for the prior year is filed. This MITT will be used by the CAP Team to conduct the post-filing review for the prior year tax return and serves as the equivalent of an application MITT for returning CAP taxpayers.
For example, if the 2020 tax return is filed on October 15, 2021, the Final 2020 MITT based on that return is due on October 15, 2021. This MITT will be used by the CAP Team to conduct the post-filing review of the 2020 tax return.
Note: Not submitting a MITT by the due date without an extension approved by the case and issue DFO or submitting an inaccurate or incomplete MITT may be treated as a significant or material failure to adhere to the terms of the CAP MOU and may result in the issuance of a Termination Letter.