Canada



World TP Reviews

Transfer pricing
Baker McKenzie

The Canadian tax department at Baker McKenzie is separated into five specialties: tax planning & transactions, tax controversy, transfer pricing, indirect tax and global wealth management. The firm represents many multinational groups, both public and private.

The recent activity of the transfer pricing team’s practice is confidential in nature. 

Barsalou Lawson Rheault

The firm of Barsalou Lawson Rheault practices in the disciplines of transfer pricing and tax controversy. It has been recognized as one of Canada’s leading law firms in transfer pricing, both at the advisory and dispute resolution level. The transfer pricing team advises clients on concerns including tax liability, transactions, reporting processes, audit procedure, competent authority proceedings and legal defense.

The firm often supports Candian subsidiaries of large corporations with their transfer pricing needs. It recently obtained the first favorable judicial review decision in Federal Court of Canada related to the CRA decision against Canadian subsidiary of Merck. The CRA had refused a downward adjustment request (247(10) of the Income Tax Act.

Bennett Jones

Founded in 1922, Bennett Jones’ corporate tax practice provides services in corporate tax, tax litigation, and transfer pricing. Tax clients consist of public corporations, private equity investors, pension funds, sovereign wealth funds, private entrepreneurs and high net worth individuals. The group works across seven strategic offices in three countries.

The recent activity of the transfer pricing team’s practice is confidential in nature.

Between 2020-2021 Bennett Jones promoted five individuals to partnership, Marshall Haughey, Barbara Kimmitt, Jared Mackey, Sophie Virji, and Philip Ward.

Blake Cassels & Graydon

Blake Cassels & Graydon has a reputation as a leading law firm in Canada. The group excels in corporate, transactional, and controversy tax matters. The tax dispute team specializes in transfer pricing concerns. Clients retain the group for advice on transfer pricing matters including planning global transfer pricing strategies, managing tax audits, objections, administrative appeals, resolution of double tax, and advance pricing agreements.

The recent activity of the transfer pricing team’s practice is confidential in nature.

Since the beginning of 2020, the firm added two new partners to its leadership. Casey Richardson-Scott was promoted to the new role, and Marie-Claire Dy joined from Dentons Canada. 

Charles River Associates

Charles River Associates offers economic, financial, and strategic expertise to corporations, law firms, accounting firms, and governments. The company is headquartered in Boston, Massachusetts, USA, but maintains many global offices, including in Canada. The groups transfer pricing practice provides a full spectrum of services, including planning, documentation, dispute resolution, risk assessments, tax valuation, and Advanced Pricing Agreements. 

The nature and impact of the firm's involvement in cross-border matters was affected by the ongoing pandemic. When serving as a transfer pricing advisor for a client in the medical device industry, the firm had to consider the positive impact Covid-19 had on the company’s operations. There were positive effects as the life sciences and medical devices sector were experiencing massive support, which was the opposite scenario for most taxpayers.

On February 3, 2020 David Kemp, previously a Partner and National Transfer Pricing Leader at Baker Tilly Canada, transitioned his transfer pricing practice to Charles River Associates’ Toronto Office.

Davies Ward Phillips & Vineberg

The 40-person tax group of Davies Ward Phillips & Vineberg works across offices in Toronto, Montréal and New York. The Canadian based department is known for their work in cross-border business transactions. The group additionally provides services in the areas of general tax advisory, and tax controversy.  

The recent activity of the transfer pricing team’s practice is confidential in nature.

Over the recent research period, the firm has expanded its partnership, promoting Andrew Ellis in their Toronto Office, in addition to welcoming new partner Marie-France Dompierre in Montréal, from Lavery Avocats.

Deloitte

Deloitte Canada’s Transfer Pricing team advises global companies in a variety of industries by providing solutions which align a company’s operational and international tax objectives. The tax resolution team provides specific transfer pricing support through inquiry handling and closure, negotiating with tax authorities, and economic and technical support. Christine Ramsay leads the transfer pricing practice. The national team consists of sixty-five members, including fourteen partners across seven offices.

Throughout the pandemic, clients have required the team’s specialized support to meet the new business landscape. Recently, it assisted a company in the service industry with evaluating, establishing, and implementing updated transfer pricing policies that more appropriately align with the group’s operating business model. Based on the analysis performed, the client decided to revise certain policies and proceed with an arrangement that realigns its transfer pricing policies with respect to IP with the presence of DEMPE functions, risks and assets within the company.

Fasken

The Fasken Martineau DuMoulin tax team is made up of over forty professionals across Canada. The firm maintains offices in five of the country’s main business centers, and houses one of the largest indirect taxation teams in Canada. It also provides Tax Litigation and Dispute Resolution services. The firm has a reputation for advising clients in the energy and natural resources industries with respect to the tax structuring and planning for large public and private M&A.

The recent activity of the transfer pricing team’s practice is confidential in nature.

Goodmans

Goodmans is a transaction-driven Canadian Tax group. The firm’s core is M&A tax, and all partners practice in this area. It specializes in public company M&A, private equity transactions, strategic acquisitions and joint ventures. Additionally, the team provides services in tax dispute resolution, commodity tax, and executive compensation.

The recent activity of the transfer pricing team’s practice is confidential in nature.

Gowling WLG

Gowling WLG’s Tax team consists of 32 professionals concentrated in Toronto. The group provides a complete, comprehensive portfolio of tax services; however, transactional tax matters make up a significant volume of the firm’s work. The group serves both domestic and foreign clients.

The recent activity of the transfer pricing team’s practice is confidential in nature.

The firm transfer pricing practice has been active over the recent research period. However, the nature of their work remains confidential currently.

Lawson Lundell

Lawson Lundell has maintained a reputation for their knowledge and expertise in advising Canadian institutional investors, including pension plans, on domestic and overseas taxation. The group has experience in Crown law, sovereign immunity, and sovereign wealth funds. Additionally, it offers services related to business taxation, including income tax, sales tax, property tax, and resource taxation.

Lawson Lundell serviced many new and existing clients over the research period, mostly from an advisory position. These relationships remain ongoing.  

Nancy Diep Joined the firm as a Partner in February of 2021. Diep had previously been a part of Blake Cassels & Graydon.

McCarthy Tétrault

The tax team at McCarthy Tétrault maintains a presence across four offices throughout Canada, Vancouver, Calgary, Toronto and Montréal. The group has three specialized departments, Tax Planning, Tax Disputes, and Sales & Commodity. Raj Juneja heads the tax practice area.

The recent activity of the transfer pricing team’s practice is confidential in nature.

The tax department has been actively recruiting, adding five new partners since late 2020 and into 2021, welcoming Robert Kopstein, Michel Ranger, Chia-yi Chua, Jeff Oldewening, and Mike Hegedus, to its team. Partner Robert Nearing, however, left the group in early 2021 for Borden Ladner Gervais.

McMillan

McMillan’s tax practice’s two main branches of service are: Tax Advisory and Tax Dispute Resolution. The Tax Dispute Resolution team possess extensive transfer pricing expertise. It serves as the primary transfer pricing counsel to many multi-national enterprises. Historically, the practice has focused on legal advisory services. However, clients have increasingly employed the firm to conduct economic transfer pricing analysis in respect to their cross-border transactions.

The recent activity of the transfer pricing team’s practice is confidential in nature.

Partner Michael Ranger left the firm in February of 2021 and joined McCarthy Tetrault.

Osler Hoskin & Harcourt

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.