Dale Hill is a partner in Gowlings' Ottawa office and is the national leader of the Gowlings Transfer Pricing and Competent Authority team. Dale works in conjunction with the Firm's National Tax Practice Group to help organizations optimize their global tax position and reduce exposure to unfavourable audit assessments through proper tax planning and implementation strategies. Dale's specialty is audit defense and dispute resolution with many countries around the world.
In addition to Dale's audit defense work, he also overseas the groups transfer pricing documentation and APA practice and is actively involved in providing litigation advice to the Firm clients from a tax perspective. Dale has worked in a variety of industries including, but not limited to, pharmaceuticals, auto, construction, consumer durables and computer software industries.
Dale's ability to solve contentious issues draws from his experience vast experience working at the Canada Revenue Agency ("CRA") at a senior level. Prior to joining Gowlings in 2005, Dale was involved in international transfer pricing and tax avoidance with the CRA for 16 years. During his tenure as a senior manager with the CRA's International Tax Directorate, he participated in more than 40 Advanced Pricing Agreements ("APAs") with numerous countries, as well as hundreds of Competent Authority requests relating to international transfer pricing adjustments involving a vast array of issues. He is also experienced in a number of other international tax areas, including interest deductibility, guarantee fees, imputed interest, notional expenses, penalties and appeals. Dale has been successful in resolving a number of controversial audit issues through successful negotiations with various tax authorities in a number of countries around the world.
Dale's expertise has been recognized many times by various institutions. In particular, his group was awarded with Canada Transfer Pricing Firm of the year Award by International Tax Review for the years 2011, 2013, and 2015. He acquired his CPA and CFP designations in 1991 and 1995, respectively, and completed the CICA in-depth tax course in 1999.
- Transfer Pricing
- Manufacturing, Sales and Distribution