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Jehad Haymour

Tax Litigation Lawyer at Bennett Jones Calgary

Partner

Julia Qian Wang

Tax Lawyer at Bennett Jones Montreal

Anna Lekach

Tax Lawyer at Bennett Jones Calgary

Associate

Canada&rsquo;s updated transfer pricing rules, effective for tax years beginning after November 4, 2025, introduce a formal framework based on &ldquo;economically relevant characteristics,&rdquo; increasing scrutiny of cross-border intra-group transactions. Life sciences MNEs face heightened audit activity, including functional interviews and expanded information requests, making robust contemporaneous documentation and proactive audit readiness essential. Early engagement of transfer pricing and dispute specialists can help mitigate reassessment risk and ensure defensible positions.

Transfer Pricing Rules in Canada Considerations for the Life Sciences Industry

Considerations for the Life Sciences Industry

Transfer Pricing Rules in Canada

Sophie Virji

The Tax Court of Canada&rsquo;s decision in ExxonMobil Canada Resources Company v. The King highlights the risks of imprecise language in internal corporate communications during CRA audits. The case demonstrates how seemingly innocuous statements can be misconstrued and relied upon to support reassessment positions. It underscores the importance of careful, deliberate drafting to mitigate audit risk and avoid unintended interpretations.

The Issue with Misconstrued Internal Statements

Learnings from ExxonMobil Canada Resources Company v. The King

The Tax Court of Canada allowed ExxonMobil Canada Resources Company&rsquo;s appeal in a significant transfer pricing dispute concerning the deductibility of feasibility study costs related to a proposed Alaska-to-North America natural gas pipeline project. The Court found that the costs were incurred for the purpose of earning income and rejected the Minister&rsquo;s transfer pricing adjustments and Part XIII tax assessment. The decision provides important guidance on transfer pricing analysis, the application of the OECD Guidelines and the evidentiary role of expert testimony in tax disputes.

ExxonMobil Wins in Tax Court in Transfer Pricing Dispute

Jared A. Mackey

Corporate Tax Lawyer at Bennett Jones Calgary

Wade Ritchie

<p><span>The <a href="https://www.budget.canada.ca/2023/home-accueil-en.html">2023 Canadian Federal Budget</a>, released March 28, 2023 (Budget 2023), proposes significant amendments to expand the application of Canada's general anti-avoidance rule. The government has invited the public to submit written comments on the proposed amendments by May 31, 2023.</span></p>

Budget 2023 Proposes Significant Amendments to Canadas General Anti Avoidance Rule

Budget 2023 Proposes Significant Amendments to Canada's General Anti-Avoidance Rule

Vasilis F. L. Pappas, FCIArb

International Arbitration Lawyer

Partner 

Melanie Teetaert

Commercial Litigation Lawyer at Bennett Jones Vancouver

Geoffrey P. Stenger

Energy, Infrastructure & Construction Lawyer | Bennett Jones Calgary

The Province of British Columbia has launched a six-week consultation on the implementation of the new Construction Prompt Payment Act. Industry stakeholders are invited to provide feedback on the Act's scope, potential exemptions and timing of implementation before the consultation closes on July 7, 2026. This update outlines the government's proposed approach and key issues under consideration.

BC Government Announces it is Soliciting Feedback on Prompt Payment Legislation

Andrew N. Disipio

Mining & Corporate Finance Lawyer | M&A, Equity & Debt Deals

Doug Fenton

Litigation Lawyer at Bennett Jones Toronto

Simon Grant

Financial Services & Regulatory Lawyer

The Supreme Court of Canada has granted leave to appeal a significant British Columbia case concerning mineral rights, Indigenous consultation and the application of UNDRIP in Canadian law. The decision will address whether courts can determine if provincial and federal legislation is consistent with UNDRIP and could have far-reaching implications for mineral claim acquisition, title certainty and natural resource project development across Canada. The ruling is expected to provide important guidance for mining companies, resource developers and Indigenous communities.

Supreme Court to Hear Landmark Case Involving Mineral Rights and Licensing Regimes

Kristopher R. Hanc

M&A and Capital Markets Lawyer at Bennett Jones Toronto

Brent W. Kraus

Corporate Governance Lawyer | Securities & Capital Markets

Co-Head of Mergers & Acquisitions Services

Christopher J. Doucet

Corporate & Mining Lawyer | M&A & Corporate Finance

On May 14, 2026, the Canadian Securities Administrators proposed wide-ranging amendments to Canada&rsquo;s issuer bid, take-over bid and early warning reporting regimes aimed at increasing flexibility, improving transparency around derivatives and reducing regulatory burden. Key changes include a potential selective repurchase exemption, enhanced disclosure for equity equivalent derivatives, and updated guidance on early warning reporting triggers and intentions. The proposals also codify certain exemptions and modernize bid mechanics in light of recent market practice and T+1 settlement.

CSA Proposes Amendments to the Issuer Bid Take Over Bid and Early Warning Regimes

CSA Proposes Amendments to the Issuer Bid, Take-Over Bid and Early Warning Regimes

Serge Dupont

Senior Advisor at Bennett Jones Ottawa

Senior Advisor

Policy and business leaders in 2026 are confronting disruptive global forces that pose daunting economic and financial risks while also transforming markets and creating avenues for growth over the next years.

Economic Outlook Mid Year 2026

A Changing World: New Risks, New Opportunities

2026 Mid-Year Economic Outlook

Alison G. FitzGerald

International Arbitration Lawyer at Bennett Jones Ottawa

Nasra Moumin

Commercial Litigation Lawyer at Bennett Jones Toronto

Global trade policy is rapidly reshaping the regulatory and commercial landscape for life sciences companies. This update explores how evolving US tariff measures, national security reviews, CUSMA renewal uncertainty and expanding export controls are affecting pharmaceutical and medical device manufacturers operating across borders. The authors also examine Canada&rsquo;s response and the growing compliance, supply chain and market access challenges facing the sector in 2026 and beyond.

The Impact of Global Trade on the Life Sciences Sector

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Daishowa-Marubeni: A Tree Fell in the Forest and the SCC Caught it!

From the Same Authors