This book includes a plain text version that is designed for high accessibility. To use this version please follow this link.
CAnAdA xxxx Contact


dale Hill Partner, Tax Services Gowling Lafleur Henderson LLP 160 Elgin Street, Suite 2600, Ottawa, Ontario K1P 1C3, Canada


Tel: 613-786-0102 Fax: 613-788-3473 Email: dale.hill@gowlings.com Website: www.gowlings.com


Firm Profile


Unique among Canadian law firms, Gowlings has a Transfer Pricing and Competent Authority Team (“TP Team”) that includes senior partners with over 50 years combined experience working for the Canada Revenue Agency (“CRA”), that is dedicated to assisting organizations optimize their global tax position and reduce exposure to unfavourable audit assessments through proper tax planning and implementation strategies. Located in Gowlings’ Ottawa office (the capital city of Canada), the TP Team has become Canada’s pre-eminent transfer pricing group, achieving appropriate results for clients when dealing with both the CRA and foreign tax authorities.


The group’s success has been witnessed by the significant growth of multinational clients over the past 7 consecutive years. Currently, the TP Team has a multinational client base of more than 60 that repeatedly rely on Gowlings to fulfil their transfer pricing needs on an annual basis. Multinationals seek out Gowlings’ TP Team’s niche expertise in the areas of Advanced Pricing Agreements and Audit Defence work, which cannot be matched by any other Canadian service provider in this field. The team’s invaluable CRA work experience allows them to provide


dale Hill


Dale Hill, Partner and National Leader of the Transfer Pricing & Competent Authority Team, is an internationally recognized and sought-after speaker and has been named as a pre-eminent practitioner in the Guide to the World's Leading Transfer Pricing Advisors, 2008 – 2011. Prior to joining Gowlings in 2005, Dale was involved in international transfer pricing with the CRA for 16 years.


Areas of Expertise • Audit defense


• Competent authority and appeals representation


40


• Transfer pricing documentation and planning


• GST matters Finance Monthly GLOBAL AWARDS 2013


During his tenure as a senior manager with the CRA's International Tax Directorate, he participated in more than 40 Advanced Pricing Agreements with numerous countries, as well as hundreds of Competent Authority requests relating to international transfer pricing adjustments involving a vast array of issues and was instrumental in the development of many important CRA policies.


extremely efficient and cost-effective solutions to clients’ complex legal matters that is simply unparalleled. The Gowlings’ TP Team is the only Canadian law firm that has a PhD economist (Dr. Jamal Hejazi), with CRA experience, dedicated solely to its transfer pricing practice. This allows for complex economic analysis that goes above and beyond traditional comparability analysis, which is often needed to settle client matters in a favourable and time efficient manner.


The TP Team is an integral part of Gowlings’ Tax Practice Group which has been ranked as a leading Canadian firm in the areas of International Tax Transaction and International Tax Planning Excellence by International Tax Review for the past four years (2008-2011). Gowlings is also the sole Canadian member of Taxand, an award-winning global organization that provides high quality, integrated tax advice on international transactions. Being a part of Taxand gives Gowlings access to tax professionals from nearly 50 countries, allowing the Firm to seamlessly deliver responsive, creative and practical tax advice to clients, wherever their tax issues arise.


Transfer Pricing Firm of the Year


the TP Team has become Canada’s pre-eminent transfer pricing group,


achieving appropriate results for clients when dealing with both the Canada Revenue Agency and foreign tax authorities.


Page 1  |  Page 2  |  Page 3  |  Page 4  |  Page 5  |  Page 6  |  Page 7  |  Page 8  |  Page 9  |  Page 10  |  Page 11  |  Page 12  |  Page 13  |  Page 14  |  Page 15  |  Page 16  |  Page 17  |  Page 18  |  Page 19  |  Page 20  |  Page 21  |  Page 22  |  Page 23  |  Page 24  |  Page 25  |  Page 26  |  Page 27  |  Page 28  |  Page 29  |  Page 30  |  Page 31  |  Page 32  |  Page 33  |  Page 34  |  Page 35  |  Page 36  |  Page 37  |  Page 38  |  Page 39  |  Page 40  |  Page 41  |  Page 42  |  Page 43  |  Page 44  |  Page 45  |  Page 46  |  Page 47  |  Page 48  |  Page 49  |  Page 50  |  Page 51  |  Page 52  |  Page 53  |  Page 54  |  Page 55  |  Page 56  |  Page 57  |  Page 58  |  Page 59  |  Page 60  |  Page 61  |  Page 62  |  Page 63  |  Page 64  |  Page 65  |  Page 66  |  Page 67  |  Page 68  |  Page 69  |  Page 70  |  Page 71  |  Page 72