We advise clients on income tax rules requiring that cross-border transfers of goods, services and intangible property between related parties occur at arm’s length transfer prices. These rules prevent multinational companies from artificially altering their related-company price structures to shift income from high-tax to low-tax jurisdictions. We regularly assist domestic and international business clients from a wide range of industries in:

		Transfer Pricing Methodology. Determining which of the five methods for determining “arm’s length” pricing is appropriate and determining the arm’s length price
		Planning. Structuring international sales and other transactions to minimize income taxes
		Documentation: Advising taxpayers on how to maintain contemporaneous documentation in support of their arm’s length transfer prices to avoid onerous income tax liabilities, interest and penalties
		Advance Pricing Arrangements (APAs). Preparing APAs and negotiating their approval by the Canada Border Services Agency (CBSA) to give companies certainty that their transfer prices will not be challenged
		Customs Valuation. Helping clients balance competing objectives and navigate the differences between transfer pricing and customs valuation rules
		Audits. Responding to transfer pricing audits
		Appeals. Appealing transfer pricing reassessments and representing clients in Federal Court

	Representative Transactions/Cases
			Prepared income tax transfer pricing reports for international transactions in goods, services and intellectual property between a Canadian electronics distributor and its foreign affiliate suppliers
			Reviewed customs, trade and transfer pricing procedures for a Canadian motor vehicle parts manufacturer and prepared report with advice and recommendations
			Prepared a transfer pricing report for goods, services and intellectual property transactions between a Canadian automobile manufacturer and its affiliated foreign parts suppliers and customers, including advising on international Income Tax Treaties

	Publications / Presentations
	August 2004 The FCA's FosterGrant Decision (Article on Customs Valuation Case) Tradeweek - Vol. 115, No. 19 Jamie M. Wilks
	December 2003 Royalties and Value for Duty GST and Commodity Tax Jamie M. Wilks
	October 2002 Opportunities for Canadian Customs Duty Relief and Recovery on Royalties and Licence Fees McMillan Bulletin Jamie M. Wilks
	June 19, 2002 Customs Valuation in Canada and Transfer Pricing in Canada "Commodity Tax for the General Tax Practitioner” conference, sponsored by the Canadian Association of Importers and Exporters Jamie M. Wilks
	June 2001 Case Comment: Mattel Canada v. MNR - Customs Law Settled In Mattel: Or Is It? Canadian Tax Journal (2001), Vol. 49, No. 6 Jamie M. Wilks