Transfer pricing has grown both in complexity and intensity; with the rising level of audit activity and resourcing at the CRA, adjustments, penalties and disputes are likely to increase. We work closely with clients to review risks and exposures before an audit happens, and we guide clients through best practices and managing documentation and compliance during an audit and dispute resolution process.
Torys’ transfer pricing team helps ensure that clients have appropriate documentation, not only of a specific transaction being undertaken, but with respect to their transfer pricing methodologies and presentation of approach through the audit stage, including making submissions on behalf of clients, submissions to competent authority, tax litigation and where appropriate, advance pricing agreements.
We work closely with clients and their financial advisers, including independent economists, and accounting firm valuators who assist with transfer pricing matters. We also help prepare clients’ staff and experts for interviews with the CRA and assist with reports and submissions, guiding clients through various processes with a view to reduce exposure to a transfer pricing adjustment.