The Canada Revenue Agency (CRA) does not have the power to compel oral interviews during tax audits, the Federal Court of Appeal (FCA) has held in Minister of National Revenue v Cameco Corp.
The CRA has increasingly requested such interviews, particularly in transfer pricing audits, but the court rejected its argument that the general power in s231.7 of the Income Tax Act to 'inspect, audit or examine' a taxpayer's books and records includes a power to compel oral responses to questions.