Canadian Transfer Pricing Audits of U.S. Companies Soar: Are you Ready?

Strategies to Minimize Tax Liability When Facing Canada Revenue Agency Reviews

Recording of a 100-minute CPE webinar with Q&A

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Conducted on Thursday, January 8, 2009

Course Materials

This seminar will offer experienced perspectives on transfer pricing audits in Canada and the U.S. to help accounting professionals prepare clients for the Canada Review Agency's increasingly difficult audit process.


The Canada Revenue Agency's transfer pricing audit activity has increased dramatically, with additional tax assessed in such audits more than doubling in the last five years -- from $300 million to $729 million. American companies with Canadian operations face particularly rugged scrutiny.

How rugged? In one recent survey, 81% of multi-national firms headquartered in Canada and 83% of those in the U.S. reported undergoing a transfer pricing audit within their global operations at least once since 2003. Accounting professionals must prepare their clients to meet these audits head-on.

Coming on board during the audit process isn't enough. Advisors can guide taxpayers during the tax planning process, help craft internal controls and policies, and ensure that proper documentation is made for international transactions.

Listen as our panel of advisors draws on their substantial experience with transfer pricing audits in Canada and the U.S. to help you prepare clients for the CRA's increasingly difficult audit process.



  1. Review of Recent Legal, Regulatory and Enforcement Developments Relevant to Transfer Pricing
    1. CRA’s recent increase in transfer pricing audits
    2. Tax Court of Canada’s GlaxoSmithKline decision
    3. Status and impact of U.S.-Canada Income Tax Treaty protocol
    4. Legal and regulatory wrap-up
  2. Managing Internal Operations to Mitigate Potential Audit Assessment
    1. Transfer pricing planning for cross border transactions
    2. Conducting internal audits
    3. Best practices
  3. Maintaining Thorough Documentation of Cross Border Transactions
    1. What types of documentation are necessary?
    2. Ensuring that documentation is thorough
    3. Anticipating contemporaneous documentation requests
    4. A foreign company’s obligations for information reporting to the CRA
  4. Understanding the CCRA Audit Process
    1. Overview of transactions likely to put a taxpayer on the CRA’s audit radar
    2. Complying with contemporaneous documentation requests
    3. Justifying pricing decisions
    4. Audit best practices and conduct


The panel will fortify you to deal with CRA auditors through:

  • Understanding recent legal, regulatory and enforcement developments in order to fully grasp the subtleties of the Canadian system.
  • Developing internal controls that anticipate and minimize problems that could lead to audit.
  • Maintaining thorough and stringent documentation standards to accurately represent a client's position.
  • Advising clients during the audit process to effectively mitigate the potential reassessment.


Merv Edwards
Merv Edwards

Managing Director
Ceteris Group

He has over 16 years of experience in transfer pricing in Canada, which includes five years with the Canada Revenue...  |  Read More

John Oatway
John Oatway
Deloitte & Touche

He manages transfer pricing engagements for large multinational corporations facing Canada Customs and Revenue Agency...  |  Read More

Salvador Borraccia
Salvador Borraccia

Baker & McKenzie

He focuses on transfer pricing and other international corporate tax issues for multinational corporations. He has...  |  Read More

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