André Bergeron explores the shifting transfer pricing landscape in Financier Worldwide roundtable

31 January 2024

André Bergeron, an economist and partner in Gowling WLG’s Transfer Pricing Group, was recently invited by Financier Worldwide to participate in a roundtable Q&A exploring the global transfer pricing landscape from several angles.

Featuring perspectives from multiple jurisdictions, the discussion focused largely on the new challenges multinational enterprises face in managing increased transfer pricing risk, particularly as tax policymakers worldwide propose significant changes to their transfer pricing regimes.

“Flexibility in approach is key to maximising tax efficiencies while maintaining compliance,” André said, in response to a question asking what essential advice he would offer multinational companies.

“For example, if a company is using ranges to determine its transfer price, it could opt to target a return within the full range, or the interquartile range, as opposed to fixing a given margin or return. This allows it to maintain consistency in its transfer pricing approach and comply with transfer pricing regulations, all while adjusting to a changing economic environment.”

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Gowling WLG’s Transfer Pricing and Competent Authority Group helps clients optimize their global tax position, ensure compliance with Canada’s transfer pricing legislation and proactively address potential disputes. This encompasses a range of services, including contemporaneous documentation, audit defense and dispute resolution through mutual agreement procedures (MAPs) and advanced pricing agreements (APAs). Learn more

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