Canada’s Transfer Pricing legislation was introduced almost 20 years ago and has always been a significant area of focus for the Canada Revenue Agency (CRA). Topics such as business restructuring and cross border interest rates and guarantee fees have evolved globally with a measure of influence from developments in Canada. The CRA was a very active participant and supporter of the Base Erosion and Profit Shifting (BEPS) initiatives of the OECD countries and we continue to see an evolving landscape of Transfer Pricing developments in Canada.
Popularly known as Canada’s sunshine capital, Calgary is also becoming known as the “Heart of the New West”. Calgary was ranked as the “Best place to work in Canada” by the Globe and Mail. Calgary is Canada’s youngest city, is home of the Canadian energy industry, and has the second highest concentration of head offices in Canada. The city offers 500+ parks and reserves provide rewarding wildlife viewing opportunities and invigorating hiking and biking trails. Calgary is close to nature, including the world renowned Banff National Park and the Rocky Mountains. The city also has plenty of hiking and biking trails, forests, wildlife parks, and lakes to enjoy. Calgary is a great place to live and an even better place to grow your career!
- Our Calgary team is the leading and growing Transfer Pricing practice in the city.
- Significant outbound work for locally-based multinationals
- Development – the size and wide variety of complexity of engagements we deal with in Calgary make it the perfect place for a manager to develop their potential. You will be provided with a unique opportunity to see issues from a different perspective, and gain valuable exposure to various OECD based approaches and methodologies.
As a member of the management team in the Transfer Pricing practice, you will take a lead role in addressing the transfer pricing requirements for our clients, including transfer pricing planning initiatives, compliance, and controversy support. You will work closely with KPMG Partners to provide clients with advice that integrates transfer pricing with other areas of tax while considering clients’ operational requirements. Your organizational skills will enable you to allocate work to junior staff where appropriate and direct the work as needed. The ideal candidate enjoys solving problems, interacting with KPMG partners and clients and sets the standard for junior staff by providing ongoing mentoring, support and opportunities for professional development. Role and Responsibilities
The successful candidate will be responsible for:
Skills & Qualifications
- Planning: development and implementation of commercially and fiscally viable transfer pricing policies and execution of effective and sustainable tax-planning strategies.
- Dispute Resolution: preparation of appropriate responses to fiscal authority challenges, determination of the strategy, performance of robust economic analyses to support existing policies and negotiation with fiscal authorities. In addition, assistance in the preparation of Competent Authority submissions.
- Compliance and Documentation: compliance with local fiscal requirements, design of transfer pricing policies and procedures, technical analysis and preparation of high quality documentation that meets the appropriate standards.
- Alternative Dispute Resolution: Assessment of the risks of fiscal authority challenges and identification of appropriate strategies in order to help manage and control our clients’ tax risks. Assistance in the preparation of Advance Pricing Arrangements (APAs) as well as negotiation with relevant fiscal authorities.
- Leadership: leading small and medium-sized client engagements and working closely with other members of our team as a senior team member. Fostering a deeply rooted sense of ownership, team and camaraderie within the practice. Providing ongoing support and mentoring for the professional development of staff.
- Growth: participation in the practices’ growth through the development of relationships in existing as well as new networks.
- Knowledge: maintaining a high level of technical knowledge, writing articles and papers and participating in and leading regular technical sessions.
- Professional Accounting Designation
- Degree in economics, statistics, math or business
- At least five years of Transfer Pricing experience for Manager level and eight years for Senior Manager
- Demonstrated commitment to client service
- Excellent team project management skills
- Trend of strong performance ratings
- Strong command of the English language
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