Managing Transfer Pricing Audits and Disputes

As transfer pricing audit activity by Canadian and foreign tax authorities continues to grow, the proactive and strategic management of the audit and appeal phases is increasingly important for taxpayers to manage tax risk and limit potential exposure.    Informed by our experience and successful track record in litigating the most significant transfer pricing cases in Canada, Osler’s Tax Controversy team invites you to join us for an in-depth panel discussion on managing transfer pricing audits and disputes. Discussion topics include:

• Strategic management of the transfer pricing audit process and taxpayer objectives in the audit phase, including such key steps as CRA requests for interviews and dealing with CRA Headquarters including Transfer Pricing Review Committee

• Impact of transfer pricing audits and transfer pricing analysis on non-income tax audits (including customs and sales tax audits), and how to strategically manage multiple audits in order to achieve the best overall tax result

• The current transfer pricing audit environment, including the impact of recent case law (Cameco and Glencore decisions) and the OECD’s recommendations on global tax reform through the BEPS project

• Strategies for objections and appeals, including our experience in negotiating settlements at different stages of the dispute process

 

Agenda

12:15 p.m. – 12:30 p.m.: Registration & Lunch 12:30 p.m. – 2:00 p.m.: Seminar