Obtaining A ‘Legal Privilege’ Opinion
A ‘privileged’ opinion can only be offered by legal counsel. Accounting firms do not operate in a privileged environment. PMR Law will provide privileged recommendations based on new resources that do not have to be disclosed to external parties.
In transfer pricing disputes, internal advisors or accounting firms that developed the transfer pricing are not able to provide this opinion or any information to Canada Revenue Agency.
The lawyers of PMR Law understand that when a taxpayer’s transfer prices are being challenged, it is essential to consolidate the resources needed to defend and explain tax strategy. PMR Law has developed protocols to be applied to client documentation that allows us to successfully maintain privilege where applicable, while carefully following the disclosure requirements that must be followed under the laws.
Documents designated with ‘legal privilege’ by a lawyer do not have to be disclosed in a transfer pricing dispute. These are the documents developed by PMR Law and the consultants it engages when undertaking a review of the taxpayer’s pricing.
PMR Law‘s objective in developing privileged information and opinions is to develop the best arguments to support a taxpayer’s case. A strong case is the basis for resolution on favourable terms.
Tax Court Litigation Experience Combined With Transfer Pricing Knowledge
Our firm has successfully defended clients’ justification for pricing in Tax Court of Canada. We develop the best data to support a transfer price, and then forcefully advocate the taxpayer’s position.
We find that CRA and the Department of Justice lawyers that take over in a tax appeal can be very open to listening to a sound logical, factual and legal argument.
Our firm has comprehensive knowledge of transfer pricing practices and methodologies. We combine this with Tax Court of Canada proven successes and provide clients with effective transfer pricing defence strategies.
Book A Consultation Today
Contact Shaun T. MacIsaac, Q. C. of PMR Law at our Calgary office today at (403) 457-9600 or by email at [email protected] and find out how we can help.