Transfer Pricing & Competent Authority


Gowling WLG is the go-to choice for multinational corporations seeking expert advice, innovative solutions and responsive documentation relating to a wide range of transfer pricing issues.

In conjunction with Gowling WLG's Tax Group, our Transfer Pricing Group helps organizations optimize their global tax position and reduce exposure to unfavourable audit assessments through in-depth tax planning and innovative implementation strategies.

Our transfer pricing team has worked with the Canada Revenue Agency for over 20 years, and has first-hand experience in the analysis and negotiation of hundreds of competent authority requests. We've also advised on advanced pricing agreements with competent authorities around the world.

Strategic solutions that mitigate risk

We can help you develop a strategic approach to transfer pricing. Our solutions will minimize your exposure to fiscal burdens, such as double taxation and non-compliance penalties.

The services we offer include:

  • Planning and advisory services
  • Comprehensive risk assessments
  • Review of existing policies and documentation
  • Preparing contemporaneous documentation - functional and economic analyses
  • Representation during the audit process
  • Appeals representation
  • Competent authority representation to relieve double taxation
  • Preparing and negotiating APAs
  • Confidential discussions with non-resident related parties
  • Adapting foreign transfer pricing studies to Canadian rules
  • Valuation of intangibles
  • Cost contribution arrangements
  • Management fees and intragroup services
  • Identifying and advising on other international tax issues

Learn more

To learn more about how we can support your transfer pricing needs, please reach out to any member of our team.