Dates and location
Pricing
Hours
Dates and location
Pricing
Hours
Description
Due to increased awareness and enforcement activities related to transfer pricing, companies more than ever need to understand and comply with the requirements of multiple tax administrations. The complexity of the transfer pricing rules and the level of documentation required may overwhelm an organization's tax department. This workshop will provide an overview of Canada's transfer pricing regime and will focus on the documentation of inter-company transactions. The workshop will also explain how to manage a Canada Revenue Agency ("CRA") transfer pricing audit and a dispute resolution process with emphasis on the competent authority process and how that can resolve double taxation.
In recent years there have been significant developments impacting transfer pricing in Canada as well as the international community. The complexities around transfer pricing has increased significantly as a consequence of the Organization of Economic Cooperation and Development's (OECD) recent project related to Base Erosion and Profit Shifting (or "BEPS"). The BEPS project was designed to curb tax avoidance and, with respect to transfer pricing, has introduced major changes to international transfer pricing guidelines. These changes not only impact future structures, especially between developed and low tax countries, but also existing structures that may come under scrutiny from CRA auditors. This workshop will investigate strategies to optimize your company's global tax position, in a post BEPS world, by placing the correct combination of functions, assets and risks in the desired location.
Schedule
- October 29, 2024, 8:30am - 12:30pm
- October 30 2024, 8:30am - 12:30pm
Key Takeaways
- Review recent developments in transfer pricing as it relates to Canada
- Discuss managing transfer pricing issues and dispute resolution
- Learn how to manage a transfer pricing audit
- Learn about arbitration rules and how they work
- Learn about the Competent Authority Process and how it can be used to resolve double taxation
- Review secondary issues pertaining to transfer pricing such as secondary adjustments, treaty time limits and PE issues
- New Developments in International Taxation and an overview of the OECD's Base Erosion and Profit Shifting ("BEPS") Initiative with a particular focus on:
- Action 8 - guidance on transfer pricing aspects of intangibles
- Action 13 - guidance on transfer pricing documentation, including a country-by-country reporting template
- Review recent Canadian court decisions on transfer pricing
Who Will Benefit
This course will be of benefit to all professionals responsible for transfer pricing and tax disputes within their organizations. This may include lawyers, accountants, controllers or VP of Finance.
How to Access The Course
This course is a live webinar. You must attend the live course to receive verifiable CPD hours. We recommend you join five minutes prior to the scheduled starting time. To get the full experience of this interactive course, use a computer that has video and microphone capabilities.
Electronic material can be accessed one week prior to the course at https://pdlms.cpaontario.ca and should be downloaded in advance.
Registration, cancellation, withdrawal and all other CPA Ontario PD policies can be found here.
Speaker(s)
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 advise to the Firm clients from a tax perspective. Dale’s ability to solve contentious issues draws from his experience vast experience working at the Canada Revenue Agency (“CRA”) at a senior level.
Jim Wilson is a partner in Gowling WLG's Ottawa office, practicing in conjunction with the Firm's National Tax Practice Group. His practice focuses on helping organizations optimize their global tax position and reduce exposure to unfavorable audit assessments through proper tax planning and implementation strategies. Jim’s tax experience involves the administration of domestic corporate and international tax with the Canada Revenue Agency (CRA) for 32 years.
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.
Pierre Alary is a partner in Gowling WLG 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.
Pierre practises in both official languages.