Pierre G. Alary Partner Transfer Pricing & National Tax Group

Speaks:  English, French

Year of Call: 2010 - Ontario

Primary phone: +1 613-786-0132

Fax: +1 613-788-3570

Email: pierre.alary@gowlingwlg.com

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Primary office:  Ottawa

Pierre G. Alary

Pierre Alary is a partner in Gowling WLG's Ottawa office, practising in the area of taxation law. His practice focuses primarily on transfer pricing, tax dispute resolution and international taxation. He is a member of Gowling WLG's Transfer Pricing and Competent Authority Group.

Pierre has represented a wide variety of clients at the audit and appeals stage of their tax disputes with the Canada Revenue Agency on both domestic and international issues. Pierre's practice covers a wide range of international tax issues such as transfer pricing, residence, cross-border employees, e-commerce, withholding tax and permanent establishments.

As a member of Gowling WLG's Transfer Pricing and Competent Authority Group, Pierre has successfully helped clients manage their transfer pricing compliance by securing Advanced Pricing Arrangements (APAs) for future taxation years. Pierre also has a proven track record in assisting clients with successfully resolving Mutual Agreement Procedure (MAP) cases. Pierre is committed to delivering tailored solutions for his clients, including through the preparation of transfer pricing contemporaneous documentation.

He is published widely in leading tax journals including WorldTrade Executive's Practical International Tax Strategies, Taxand's Take, BNA International's Transfer Pricing International Journal, Global Tax Watch, Transfer Pricing Forum, The International Tax Review and Tax Planning International Review. Pierre was also cited in the Practitioner's Income Tax Act, 2022, 62nd edition.

Pierre practises in both French and English.

Career & Recognition

Filter timeline:
  • 2010

    • Qualifications (Year of Call/Admission, etc.)
      Year of Call, Ontario
  • 2009

    • Education
      University of Ottawa, LLB (cum laude)


  • Canadian Bar Association
  • Law Society of Ontario
  • Pierre G. Alary, "Managing Transfer Pricing" course, CPA Canada.
  • ​Pierre G. Alary, Andre Bergeron, Dale Hill, June 22, 2022, "Update - What's Up at CRA and The Fundamentals and Key Issues Relating to Transfer Pricing​"
  • Pierre G. Alary, November 2, 2021, "When to File (and When to Not File) a Service Complaint against the CRA"
  • Pierre. G. Alary, September 28, 2021, "How to Not Manage a CRA Audit – The Amdocs Decision"
  • Dale Hill, Pierre G. Alary, Andre Bergeron, July 13, 2021, "Canada's APA Program: An Overview"
  • Pierre G. Alary & Multiple Authors, April 20, 2021, "Budget 2021: Canada's COVID-19 Recovery Budget"
  • Pierre G. Alary & Multiple Authors, May 20, 2019, "Budget 2019: Positioning for a Fall Election"
  • Dale Hill and Pierre G. Alary, July 2014, "Resolving Transfer Pricing Disputes in Canada"
  • Jim Wilson, Pierre G. Alary, and Colleen McMullin, January 2013, "Three-year Statute of Limitation on Refunds of "Overpayments" for Corporations: Has CRA Opened Pandora's Box?", Practical International Tax Strategies
  • Jim Wilson and Pierre G. Alary, October 2013, "Canada and U.S. Announce Agreement regarding PE Attribution of Income Principles under Canada-U.S. Treaty," Bloomberg BNA Transfer Pricing International Journal
  • Pierre G. Alary, Sandra Mah, and Jim Wilson, November 2012, "Permanent Establishments – Canadian Update"
  • Pierre G. Alary, Dale Hill, and Mark Kirkey, October 2012, "Glaxo: Supreme Court of Canada Rules on First Transfer Pricing Case," Practical International Tax Strategies
  • Jim Wilson, Helena Plecko and Pierre Alary, January 2012, "Outdated Provision of Canadian Income Tax Act Taxes Foreign Service Providers A Solution Looking for a Problem," Practical International Tax Strategies.
  • Jim Wilson and Pierre G. Alary, "Permanent Establishment Issues for Non-Resident Parent Companies with Subsidiaries in Canada," The 2012 Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada, 14th Edition, January, 2012. (Short name: 2012 Lexpert ALM 500), January 2012
  • Jim Wilson and Pierre G. Alary, December 2011, "Paragraph 212(1)(a): The Perils of an Obsolete Tax Provision," International Tax Strategies
  • Jim Wilson and Pierre G. Alary, December 2011, "Federal Court of Appeal Upholds Lower Court Decision"
  • Jim Wilson and Pierre G. Alary, December 2011, "New Protocol to Canada-Barbados Treaty – Barbados Regains Advantage Over TIEA Countries"
  • Jim Wilson and Pierre G. Alary, CRA Provides Much Needed Guidance by Issuing PE Ruling, The International Tax Review, September, 2011
  • Jim Wilson and Pierre G. Alary, Deemed Services PEs - Subcontractors vs Agents - CRA Adds Fuel to the Fire, BNA Transfer Pricing International Journal, May 2011
  • Jim Wilson and Pierre G. Alary, TCC Rules on First Canadian Non-Discrimination Treaty Case: Saipem UK Limited v. The Queen, Taxand's Take, February 2011
  • Jim Wilson, Pierre G. Alary, Dale Hill, Mark Kirkey, and Jamal Hejazi, GE Capital Canada: FCA Dismisses Crown's Transfer Pricing Appeal on Guarantee Fees, Practical International Tax Strategies, January 2011
  • Federal Court of Appeal "gets it right" and overturns Tax Court's Glaxo ruling, BNA Global Tax Watch, November 2010

Client work

Client work
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