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Transfer Pricing

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Transfer pricing is a high priority enforcement area for the Canadian revenue authorities and those of its major trading partners. As governments intensify their scrutiny of cross-border arrangements and businesses seek growth in foreign markets, transfer pricing risks, and opportunities, grow. In this environment, businesses require sophisticated but practical transfer pricing advice and representation. While transfer pricing has traditionally been considered an income tax matter, increasing border enforcement means that the customs and commodity tax implications of related party imports must be considered in developing and implementing sound transfer pricing policies.

At Bennett Jones, we deliver a unified approach to tax and customs transfer pricing where enterprises transfer goods, services and/or intellectual property across borders. Working collaboratively with economists and other transfer pricing consultants, we seek to maximize transfer pricing benefits for our clients while mitigating risk. Where transfer pricing inquiries or disputes arise, we offer experienced, effective counsel to defend our clients' interests.

Structuring: efficient tax and customs transfer pricing structuring for related party exchanges of goods, services, and/or intellectual property

Contemporaneous Documentation: to meet applicable tax and customs standards

Compliance Review: to identify opportunities and areas of risk and to establish best import practices

Audit Representation: effective advocacy on behalf of taxpayers and/or importers involved in transfer pricing audits and investigations

Competent Authority Negotiations: effective advocacy for taxpayers seeking Competent Authority relief from multiple taxation

Dispute Resolution & Litigation: experienced representation to tax authorities and courts and tribunals at all levels in transfer pricing and related tax and trade litigation

APAs & Rulings: to bring certainty to taxpayers' and importers' arrangements

Voluntary Disclosures: to permit the orderly reporting of prior non-compliance while mitigating exposure to penalties

Key Contact

  • Edwin G. Kroft KC Edwin G. Kroft KC, Partner
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Recent Experience

Smith Kline Beecham Animal Health Inc., in its litigation in the Tax Court of Canada and Federal Court of Appeal and related settlement of its transfer pricing adjustments.
Advising a U.S. accessories retailer on the establishment of multiple business lines in the Canadian market involving income tax, GST and customs advice and the commissioning of a transfer pricing study to satisfy contemporaneous documentation requirements.
Advising a Canadian apparel distributor on the importation of goods, the licensing of IP from a related party and the commissioning of a transfer pricing study to satisfy contemporaneous documentation requirements.
Advising a U.S.-headquartered clean technology business on the importation of goods to Canada, including tariff classification and GST implications.
Advising a multi-national mining company on ongoing international and intra-Canadian transfer pricing issues.
Representing a Canadian-headquartered services business in connection with a proposed transfer pricing reassessment by the Canada Revenue Agency effectively subjecting all the revenues of its foreign subsidiary to Canadian tax.
Representing a European-headquartered manufacturer in a voluntary disclosure and trade verification audit of customs transfer pricing with issues including those giving rise to a claim for duty refunds in connection with downward transfer pricing adjustments.
Advising a Canadian subsidiary of a retail distributor on a reassessment proposal disallowing royalty expenses.
Representing a number of Canadian taxpayers on reassessment proposals disallowing management fees and imposing transfer pricing penalties.

Recent Recognition

World Transfer Pricing
Ranked, Transfer pricing

Insights, News & Events

Announcements

Bennett Jones Nominated for Canada Transfer Pricing Firm of the Year

August 13, 2021
       

Articles

Transfer Pricing in the Time of COVID-19

February 19, 2021
       

Blog

Supreme Court of Canada Declines to Hear the Cameco Landmark Transfer Pricing Case

February 18, 2021
       

Related Services

International Trade & Investment
Tax
Tax Litigation & Dispute Resolution
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