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Pierre Alary is a partner in Gowling WLG’s Ottawa office, practising in the area of taxation law. His practice focuses primarily on tax dispute resolution, international taxation and transfer pricing. He is a member of Gowling WLG's Transfer Pricing and Competent Authority Group.
Pierre has represented a wide variety of clients at the audit and appeals stage of their tax disputes with the Canada Revenue Agency on both domestic and international issues. Pierre’s practice covers a wide range of international tax issues such as residence, cross-border employees, e-commerce, withholding tax and permanent establishments.
Pierre is one of the co-hosts of Gowling WLG’s Tax Dispute Resolution Monthly Update webinar. He is published widely in leading tax journals including WorldTrade Executive’s Practical International Tax Strategies, Taxand’s Take, BNA International’s Transfer Pricing International Journal, Global Tax Watch, Transfer Pricing Forum, The International Tax Review and Tax Planning International Review. Pierre was also cited in the Practitioner’s Income Tax Act, 2021, 60th edition.
André Bergeron is a partner in Gowling WLG’s Ottawa office, practising in the Transfer Pricing and Competent Authority Group.
André’s practice focuses on transfer pricing analysis, mutual agreement procedures (MAPs) and advanced pricing agreements (APAs) to help clients optimize their global tax position. In addition, drawing on his extensive experience working with the Canada Revenue Agency (CRA), he provides organizations with strategic advice to support their audit defense and transfer pricing position during international audits.
Prior to joining Gowling WLG, André was a senior economist at the CRA’s Competent Authority Services Division. During the 10 years he spent in this role, he participated in numerous APAs and MAPs with many foreign governments, namely in the United States, South Korea, Denmark, Netherlands, Switzerland, China, India and Chile. This work, and the resulting negotiations, involved several tax issues in many industries, including pharmaceuticals, automotive, gaming, natural resources, communications and electronics. In addition, he also worked on various international audits related to international transfer pricing transactions.
