Transfer Pricing

In recent years, the Canada Revenue Agency (CRA), together with other tax authorities around the world, has identified transfer pricing as the single most important international tax audit issue. Consistent with this and a commitment to ensuring compliance, CRA has increased its staff and expertise at all levels from audit at the field level to the head office divisions responsible for international audit, and the Competent Authority Services. Companies in Canada (either headquartered or operating) are now regularly subject to transfer pricing audits. As a result, businesses engaged in international trade must focus on strategic planning to ensure compliance with Canada’s statutory rules.

Blakes is recognized for our specialized knowledge and skill in resolving a wide range of complex tax disputes, including those involving transfer pricing issues. Clients retain us for advice on transfer pricing matters because of our long history of successfully advising multinationals on all aspects of transfer pricing, including planning global transfer pricing strategies, objections, administrative and other appeals, and resolution of double tax through competent authority proceedings and advance pricing agreements. Applying our extensive depth of experience, we help clients understand the legal and administrative standards and fulfill documentation and reporting requirements. Blakes has also represented clients in important transfer pricing cases before Canadian courts and is consistently recognized and ranked in leading global ranking publications.

Members of the Blakes Transfer Pricing practice also have long-standing working relationships with and are active in a number of institutions and organizations, including teaching at major law schools (New York University, University of Toronto and Osgoode Hall Law School), acting as executive fellow of the School of Public Policy at the University of Calgary and sitting as members of Council for IFA Canada, and the Permanent Scientific Committee of IFA.