Transfer Pricing & Competent Authority

Planning with purpose. Defending with insight.

Optimize your global tax standing with strategic clarity and insider advice—delivered by an elite team of lawyers, economists, and accountants who see the whole picture.

Transfer pricing is about more than complying with evolving tax rules. It’s about safeguarding your business from costly disputes, reputational risks, and operational delays. Whether you're navigating complex audits, pursuing bilateral tax relief, or validating intercompany arrangements, the stakes are high, and the pressure to get it right is real.

Our multidisciplinary team harnesses decades of experience working closely with the Canada Revenue Agency (CRA)’s Competent Authority Services Division and the Appeals Branch, offering you informed solutions that are both proactive and protective. From audit defense to dispute resolution, we help you position your business with confidence to limit exposure to costly transfer pricing adjustments.

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Transfer pricing strategies that keep you in control

Discover the advantage of a uniquely integrated practice, where seasoned legal, economic and tax expertise come together to push your business forward. Here’s what sets us apart:

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Multidisciplinary strength, built for real-world risk: Our bench runs deep and wide. Your file is handled by a tight-knit team of former high-ranking CRA officials, legal professionals, economists, and accountants. This 360-degree insider perspective gives us a powerful advantage in anticipating the government’s approach, assessing your risk exposure, and crafting persuasive positions from the outset.

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Boutique experience, broad perspective: You won’t be handed off. Our senior leaders roll up their sleeves and personally lead each engagement, offering bespoke service with a human touch. This personal, partner-led approach has made us a trusted advisor to many large enterprises, including those with their own in-house transfer pricing teams, who routinely rely on us to provide expert second opinions and stress-test their strategies.

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Privileged protection: Unlike with most accounting firms, our advice benefits from solicitor-client privilege, giving you a layer of protection that’s essential when sensitive communications could become subject to subpoenas or litigation. When the situation turns contentious, we help you manage it discreetly and strategically.

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Integrated business advice: Transfer pricing doesn’t operate in a vacuum. Whether you're planning an acquisition, launching a Canadian subsidiary, or restructuring operations, our transfer pricing advice aligns with the broader legal and commercial context of your business. We work seamlessly with Gowling WLG’s tax, M&A, and international business teams to deliver harmonized, forward-looking support.

“Transfer pricing is about more than getting it right on paper—it’s about protecting what you’ve built and telling your company’s story to tax authorities. Our role is to help you navigate complexity with clarity, anticipate risk before it becomes a problem, and stand beside you when the pressure’s on. We lead with insight, but just as importantly, we lead with integrity.”

- André Bergeron, Co-Leader, Transfer Pricing & Competent Authority Group

Full-spectrum solutions

Whether you're setting policy or negotiating treaty relief, we guide you through every stage of your transfer pricing journey. Wherever you are in the lifecycle, we build solutions that align with your business and stand up when it matters most. Explore our services:

Audit defence and dispute resolution

Facing a CRA audit or proposed reassessment? We act quickly to protect your position, manage interactions with the tax authority, and respond with persuasive, technically sound arguments—always mindful of your broader business priorities.