Baker McKenzie’s transfer pricing team is among the top players in Canada. Christopher Raybould is the Canadian transfer pricing practice leader and the director of economics for Baker McKenzie in Toronto. The firm’s transfer pricing practice serves its clients from the planning stage through dispute resolution and litigation. The group advises Canadian companies and subsidiaries of foreign companies in different sectors, including manufacturing, automotive, consumer, oil and gas, forestry and technology.
Over the research period, the team handled remarkable transfer pricing matters.
Baker Tilly Canada’s transfer pricing practice is a key practice of the firm. The group represents domestic and international companies in various transfer pricing matters in different sectors, including automotive, manufacturing, real estate, oil and gas, mining and investment funds. David Kemp is the national leader of the global transfer pricing and dispute resolution practice and is also an executive member of Baker Tilly International’s global transfer pricing committee.
Over the research period, the team performed different economic analyses and worked on complex transfer pricing issues.
Barsalou Lawson Rheault is a leading boutique firm very strong in transfer pricing, both at the advisory and dispute resolution level. The team represents clients in managing transfer pricing risks and it assists taxpayers seeking to apply for mutual agreement procedures, APAs and accelerated competent authority procedures. Senior partners Pierre Barsalou and Sébastien Rheault are key contacts at the firm. The team also includes partners McShane Jones and Josée Pelletier. Their focus is on transfer pricing and tax controversy.
In the last 12 months, the group resolved a number of transfer pricing tax disputes for Canadian subsidiaries of foreign MNE groups at the administrative audit or appeals levels the Canada Revenue Agency, as well as at the competent authority level. Clients included multinational enterprises in particular in the pharmaceutical, biotechnology, aerospace and mining industries.
“They did a great job, I will not hesitate to hire the firm again.”
“Pierre Barsalou and his team have a strong understanding on how the law is applied, which is a critical factor in transfer pricing.”
Bennett Jones’s transfer pricing practice is a key area of the law firm, in addition to its tax department. The team provides tax and customs transfer pricing structuring for related party exchanges of goods, services and intellectual property across borders. The group works with economists and consultants to maximise transfer pricing and mitigating risks. Edwin Kroft is the head of tax litigation and dispute resolution. He has also an extensive experience in transfer pricing.
The team, over the research period, advised a number of APAs and MAPs for different companies. In addition, the group worked on audits, appeals and litigation in the tax court of Canada and the federal court relating to guarantee fees and other cross border payments such as management fees and royalties.
Last year, the firm hired Edwin Kroft from Blake Cassels & Graydon. Partner Deborah Toaze, who also specialises in transfer pricing joined from the same firm.
Blake Cassels & Graydon’s transfer pricing team maintains a dominant position in Canada. The team is recognised for its knowledge in dealing with a range of complex tax and transfer pricing disputes. Overall, the group has a long history of successfully advising Canadian, US, European and Asian multinationals on issues such as planning global transfer pricing strategies, cost-sharing agreements, competent authority proceedings and securing APAs.
In the last year, the team worked on numerous transfer pricing matters. All of them remained confidential.
Tax law has been a key focus for Davies since its foundation. The transfer pricing practice also plays an important role in the firm. The group advises domestic and international companies in different sectors, including mining, communications, automotive, cannabis, energy, technology, real estate and agriculture.
In the last year, the team worked on an impressive number of cross-border transactions that involved also transfer pricing matters. For example, the group advised Ivanhoé Cambridge, Michelin Group and Bank of Montreal.
Deloitte’s transfer pricing team has a dominant position in Canada. It advises on complex transfer pricing audits and it represents domestic and international companies. The group comprises economists, international tax specialists and former Canada Revenue Agency senior officials. Over the research period, the group conducted many transfer pricing analyses.
Gowling WLG’s transfer pricing practice is very strong. The team, together with the national tax practice group, helps organisations optimise their global tax position and reduce exposure to unfavorable audit assessment through tax planning and implementation strategies. Dale Hill is the national leader of the firm transfer pricing and competent authority team. With significant experience dealing with Asian governments and businesses, Dale assists the firm’s largest Asian clients in optimising their operations from a transfer pricing perspective.
In the last 12 months, the team worked on several transfer pricing matters. It represented multinational companies in different sectors, including the pharmaceuticals, auto, construction and computer software industries.
The KPMG team has the largest tax practice in Canada with more than 1,500 tax professionals and 283 partners. The firm has a dominant position in transfer pricing practice and it has an emphasis on transfer pricing planning, dispute resolution and compliance. Partners and professionals provide transfer pricing legal advice and have deep transfer pricing litigation and controversy expertise.
The transfer pricing practice contributes to organisations such as TEI, IFA, and Canadian Tax Foundation. The practice has also developed an expertise in economic consulting services that extends beyond transfer pricing.
McMillan’s transfer pricing practice is very active. The team advises multinational enterprises and it provides studies on behalf of clients. In addition, it represents clients before Canadian tax authorities with regard to various transfer pricing disputes. Mickey Yaksich, a senior partner in the firm’s tax group, has extensive experience advising clients in most industrial sectors, with a particular emphasis on the automotive and pharmaceutical industries. In addition, partner Michel Ranger is the co-author of the seminal textbook on transfer pricing in Canada.
The team strengthened itself during the research period with the addition of senior economist Yongchong Mao, hired from EY
Osler Hoskin & Harcourt excels in transfer pricing practice. The team has been involved in some of the most significant transfer pricing disputes. For examples, the firm is counsel of record on two of the largest and most significant tax litigation cases in Canada, such as Cameco and Wheaton Precious Metals. These cases are precedent setting and the outcomes of both have been watched by tax advisers around the world. Other key clients included Burlington Resources Finance Company and the Conoco Funding Company.