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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

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• 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.