Transfer Pricing Competent Authority

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.

We represent clients in Mutual Agreement Procedure (MAP) and Accelerated Competent Authority Procedure (ACAP) proceedings under Canada’s tax treaties, pursuing fair and timely relief from double taxation. Our close understanding of CRA and treaty partners enables us to craft strategies that move negotiations forward.

When the CRA issues a reassessment you don’t agree with, time is critical. We move quickly to prepare a well-grounded Notice of Objection that preserves your rights and positions your case strategically. We work with your internal teams and advisors to assess the reassessment, develop compelling arguments, and navigate the dispute resolution process with a focus on minimizing financial exposure. If the CRA issues a notice of confirmation, we’re ready to prepare a Notice of Appeal and advocate for your position before the Tax Court of Canada.

We guide you through bilateral and multilateral APA negotiations with tax authorities, helping you gain long-term certainty while minimizing risk and administrative burden.

Even seasoned in-house teams turn to us for strategic guidance. Whether you're entering a new jurisdiction or navigating a grey area, we deliver sharp, commercially grounded perspective supported by benchmarking analysis and deep experience, not guesswork.

Staying compliant with Section 247 of Canada’s Income Tax Act means more than getting your numbers right. It requires timely, defensible documentation that supports your intercompany pricing. We help you meet CRA expectations with rigorous contemporaneous documentation and proactive strategies that reduce audit risk and penalty exposure.

From intercompany agreements to transfer pricing contemporaneous documentation reports, we help you build robust documentation that aligns with OECD guidelines, local requirements, and your unique operating model, reducing the risk of challenges down the line.