Transfer Pricing

Osler is ideally positioned to assist clients facing intensified scrutiny of transfer pricing policies and strategies in Canada and around the world. Our transfer pricing expertise is comprehensive and our team has significant experience in:

• Strategy development and planning — Our Tax experts provide strategic advice in respect of structuring intercompany transactions and developing transfer pricing methodologies in alignment with clients’ objectives and interests.
• Disclosure and compliance requirements — Our Tax team works with clients on addressing complex multi-jurisdictional compliance requirements, advising on coherent and defensible contemporaneous documentation while helping to protect sensitive and confidential business information.
• Exposure and risk assessment — In the context of the legal framework and global tax risk environment, Osler advises on transfer pricing issues arising in domestic and cross-border transactions, profit allocations, intercompany financing structures, and reorganizations.
• Tax controversy — Our team advises and represents clients on international tax and transfer pricing audits, administrative objections and appeals, mutual agreement procedures under bilateral tax treaties, as well as clients seeking bilateral or multilateral advance pricing arrangements as a potential means of mitigating risk.
• Tax litigation — Our team advises on the conduct of the most significant transfer pricing cases before Canadian courts, including as counsel in the first transfer pricing case to consider the scope and application of the current Canadian transfer pricing legislation, the first and only transfer pricing appeal to be heard by the Supreme Court of Canada, and the first case to provide guidance on the transfer pricing “recharacterization” rule.