Transfer Pricing

  • Transfer pricing documentation and compliance
  • Transfer pricing planning and policy development for cross-border intercompany transactions
  • Transfer pricing audit defence and dispute resolution
  • Transfer pricing risk assessment
  • Due diligence and tax accrual reviews from a transfer pricing perspective
  • Advance Pricing Arrangements (APAs)
  • Economic benchmarking analyses
  • Attribution of income for Permanent Establishments

I n the current state of affairs of international tax, transfer pricing and preventive base erosion profit shifting (“BEPS”) initiatives, non-compliance with transfer pricing regulations represents a significant risk for the financial performance, tax management and reputational governance of public and private companies. Corporate groups investing in Canada and Canadian corporations investing abroad need to be more diligent about the development and implementation of their transfer pricing policies to strike a balance between business goals, compliance requirements, exposure management, and planning opportunities.

Our transfer pricing practice can assist you to prepare transfer pricing documentation and support your filing position reducing the risk of tax re-assessments, penalties or potential double taxation. We can also support you in developing and implementing transfer pricing policies and in executing forward-looking planning opportunities aligned to your cross-border business objectives. Call us today to find out how our transfer pricing department can help you fulfil your international taxation needs!