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Transfer Pricing and Tax Litigation in the Mining Sector

Fasken Martineau's PDAC 2017 Seminar Series
Where Fasken Martineau
333 Bay St., Suite 2400
Bay Adelaide Centre
Toronto, ON
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Presenters: Jenny Mboutsiadis, Christopher Steeves

The mining sector, along with other industries are entering an era of greater scrutiny by tax regulators. This is because Canada and about 100 other jurisdictions are dedicating considerable attention and resources to enforcing tax compliance and cracking down on tax avoidance - and they are looking closely at multinational enterprises.

The last couple of years has seen a marked increase in the Canada Revenue Agency’s reliance on transfer pricing rules, anti-avoidance provisions, and the doctrine of sham to keep multinational corporations’ profits inside Canada and subject to Canadian taxation. The tax reassessments against Cameco and Silver Wheaton, for example, involve billions of dollars of tax and interest. The mining sector is particularly susceptible to tax regulators’ scrutiny under the transfer pricing provisions because cross-border relationships and multi-jurisdictional activities are both necessary and common in this industry.

The speakers in this seminar will:

  • Explain the current transfer pricing rules and the OECD’s proposed changes to them through the implementation of its Base Erosion and Profit Shifting (“BEPS”) initiative, and corporations in the mining sector can be affected;
  • Describe the typical ways the Canada Revenue Agency can challenge mining corporations in the context of the transfer pricing provisions;
  • Describe the types of corporate structures and transactions in the mining sector that are prone to challenge; and
  • Review past and current cases in the Tax Court of Canada involving mining corporations in an effort to learn what to avoid


  • 07:30 - 08:00 EST Registration and Breakfast
  • 08:00 - 09:00 EST Seminar and Q&A


This seminar is complimentary


This is an in-person seminar only


Please RSVP by filling in the form below

For more information

Cassandra Patrick
+1 416 943 8976