Gowlings Transfer Pricing

OVERVIEW

During the past decade, multinational organizations have been expanding into global markets at an unprecedented rate and governments around the world are taking notice of the increased risk of fiscal erosion. Due to increased awareness and enforcement activities related to transfer pricing, companies need to comply with the requirements of multiple tax administrations. The complexity of the transfer pricing rules and the level of documentation required may overwhelm an organization's tax department.

Proper planning can position an organization to optimize its tax situation by properly placing the correct combination of functions, assets and risks in the desired jurisdiction. With our extensive knowledge of the transfer pricing rules and current government policies we can help your company establish favourable and defensible transfer pricing policies in advance of an audit, defend your company's current transfer pricing structure, or develop prospective plans through an advance pricing agreement. See Gowlings Transfer Pricing Services.

The Gowlings transfer pricing team has over 20 years of transfer pricing and competent authority experience with the Canada Revenue Agency ("CRA"). Our professionals have been involved, first hand, in the analysis and negotiations of hundreds of competent authority requests and advance pricing agreements with competent authorities around the world.

Gowlings Transfer Pricing Services

The Gowlings Transfer Pricing and Competent Authority Team can help you develop a strategic approach to transfer pricing and solutions that will mitigate fiscal burdens such as double taxation and non-compliance penalties. Our services include:

• Planning and Advisory Services
• Comprehensive Risk Assessment
• Review 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
• Valuation of Intangibles
• Cost Contribution Arrangements
• Management Fees and Intra-Group Services
• Identifying and Advising on Other International Tax Issues

Our Transfer Pricing & Competent Authority Team

When dealing with the CRA, who better to have in your corner than the government's former transfer pricing and competent authority senior analysts… now working exclusively for Gowlings.

Dale Hill, National Leader Transfer Pricing & Competent Authority Group
Jamal Hejazi, Ph.D, Chief Economist
Mark Kirkey, Senior Director

Multinational organizations are expanding into global markets at an unprecedented rate and governments around the world are taking notice of the increased risk of fiscal erosion. Due to increased awareness and enforcement activities related to transfer pricing, companies need to comply with the requirements of multiple tax administrations. The complexity of the transfer pricing rules and the level of documentation required may overwhelm an organization's tax department.