Osler Hoskin & Harcourt

Canada

World TP Reviews

Transfer pricing

Monica Biringer and Patrick Marley co-chair the tax department at Osler Hoskin & Harcourt. They oversee a team of 65 lawyers over five offices in Canada: Montréal, Ottawa, Toronto, Calgary and Vancouver. Tax planners and litigators operate as an integrated unit to provide comprehensive advice. The firm has been recognized as a market leader with tax controversies, but provides a range of services including corporate tax planning, negotiation of mergers, indirect taxation, and more.

The firm recently took part in the first case involving the 'recharacterization' of transfer pricing provisions in section 247 of the Canadian Income Tax. Cameco employed the team as counsel for the litigation.The question of this case is whether the profits realized by a subsidiary based in Switzerland on uranium purchased from and sold to its parent company should be attributed to the Canadian based corporation. The matter is expected to set critical tax code precedents.

Osler Hoskin & Harcourt welcomed Amanda Heale as a new partner in April of 2021. Heale was hired from Blake Cassels & Graydon.