Dale Hill

Canada
Transfer Pricing

Dale Hill is the key Canadian member of Taxand's global transfer pricing team. He is based in Taxand Canada where he leads Gowling Lafleur Henderson’s Transfer Pricing and Competent Authority team and works with the National Tax Practice Group to help companies optimise their global tax position and reduce exposure to audit assessments through tax planning and implementation strategies. Since 1997, and before joining Canada’s Taxand practice, Gowling Lafleur Henderson in 2005, Dale was involved in international transfer pricing with the Canada Revenue Agency (CRA). 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 on vast array of issues. He is also experienced in other international tax areas including interest deductibility, guarantee fees, imputed interest, notional expenses, tax avoidance, ACAP, penalties and appeals. In 2004, Dale led the development of a national field strategy that defined the working relationships among the CRA's Competent Authority, tax services offices, appeals and head office with respect to audit adjustments to Canadian taxpayers and audit adjustments initiated by foreign countries. Dale has published widely in leading tax journals including Tax Notes International, North American Free Trade and Investment Report, as well as Lawyers Weekly. Dale graduated with an honours BComm from St. Mary's University in Halifax, Nova Scotia. He acquired his CMA and CFP designations in 1991 and 1995 respectively, and completed the CICA in-depth tax course in 1999.

Areas of Expertise

• Transfer Pricing
• Advanced Pricing Agreements
• Competent Authority Requests

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