The Canada Revenue Authority (CRA) has just released its 2014-2015 APA program report (covering the 12 months to 31st March 2015). The report provides statistics in respect of all APA cases managed during the period. For the full report, see:
Key points summary:
APAs continue to be attractive for certain taxpayers in certain situations. The data reported by the CRA tends to confirm the historic trend for auto manufacturers , chemical companies, or other tax payers with large intra-group flows of tangible goods to be particularly attracted to APAs given the tax certainly they offer. Whether this demand stems from particular characteristics of these industries/companies or simply because these taxpayers tend to be audited more frequently  is unclear.
 Since Chrysler, Ford, GM, Honda, and Toyota run 12 plants in Ontario (making it the only province or state in North America with five OEMs), you don’t need to be Hercule Poirot to guess who may be currently involved in an APA discussion with the CRA.
 APAs are often concluded on the back of an audit and tax inspectors (in our experience) like auditing manufacturing companies where business models are often easier to understand/challenge than say financial services companies or technology companies.