Transfer Pricing Chat: Amanda Heale, Canadian Tax Partner

Canada’s transfer pricing rules have been going through a period of increased scrutiny following the federal government’s loss in a major dispute with global uranium miner Cameco Corp. at the Federal Court of Appeal in 2020.

The Finance Department has yet to release a public consultation on ways to reform transfer pricing rules promised in April 2021, while the country’s tax authority, the Canada Revenue Agency, has several transfer pricing cases working their way through the courts.

Bloomberg Tax spoke with Amanda Heale, a partner at Osler, Hoskin and Harcourt LLP in Toronto, to discuss how federal policy and ...