Course content

    1. Presentation

    2. Recording

About this course

  • $69.00
  • 1.5 CPD hours
  • June 22, 2022 – 11:00 AM

Course Description

Hear from some of Canada’s top Transfer Pricing specialists for this important session regarding:

  • What is transfer pricing?
  • What is a transfer pricing audit and what are the best practices for managing one?
  • How does CRA work with all departments in dealing with transfer pricing adjustments and how they are resolved?
  • Understanding the recent CBC articles (e.g. Ashley Burke’s May 3, 2022 article). What is behind all the negativity and why what CRA did for the taxpayer is appropriate.

If you deal with transfer pricing internally for your employer, or as a transfer pricing professional, don’t miss this session.

Instructor(s)

Pierre Alary

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.

Andre Bergeron

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.

Dale Hill

Dale Hill is a partner in Gowling WLG's Ottawa office and is the national leader of the Gowling WLG Transfer Pricing and Competent Authority team. Dale works in conjunction with the Firm's National Tax Practice Group to help organizations optimize their global tax position and reduce exposure to unfavourable audit assessments through proper tax planning and implementation strategies. Dale’s specialty is audit defense and dispute resolution, where he has been instrumental in preventing various tax authorities, in North America, Europe and Asia, from raising costly transfer pricing adjustments and penalties on some of the world’s largest multinational companies.

In addition to Dale’s audit defense work, he also oversees the groups transfer pricing documentation and APA practice and is actively involved in providing litigation advice to the Firm clients from a tax perspective. With significant experience dealing with Asian governments and businesses alike, he assists the Firm’s largest Asian clients in optimizing their global operations from a transfer pricing perspective. Dale has worked in a variety of industries including, but not limited to, pharmaceuticals, auto, construction, consumer durables and computer software industries.