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Gowlings is the go-to choice for multinational corporations seeking expert advice, innovative solutions and responsive documentation relating to a wide range of transfer pricing issues.
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Gowlings’ Transfer Pricing and Competent Authority Group, in conjunction with the Firm’s Tax Practice Group, helps organizations optimize their global tax position and reduce exposure to unfavourable audit assessments through in-depth tax planning and innovative implementation strategies.
We have worked with the Canada Revenue Agency for over 20 years, and have first-hand experience in the analysis and negotiations of hundreds of competent authority requests and advanced pricing agreements with competent authorities around the world.
We can help clients develop a strategic approach to transfer pricing and solutions that will minimize fiscal burdens such as double taxation and non-compliance penalties.
Our services include:
- Planning and advisory services
- Comprehensive risk assessments
- Review of existing policies and documentation
- Preparing contemporaneous documentation – functional and economic analyses
- Representation during the audit process
- Appeals representation
- Competent authority representation to relieve double taxation
- Preparing and negotiating APAs
- Confidential discussions with non-resident related parties
- Adapting foreign transfer pricing studies to Canadian rules
- Valuation of intangibles
- Cost contribution arrangements
- Management fees and intragroup services
- Identifying and advising on other international tax issues
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