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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 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

Edwin G. Kroft KC

Tax Litigation Lawyer at Bennett Jones

The 24th edition of Bennett Jones on Tax Disputes, published on <a rel="noopener noreferrer" rel="noopener noreferrer" href="https://www.gettaxnetpro.com/" target="_blank">Taxnet Pro</a> by Thomson Reuters, features an overview of recent cases of note and cases under appeal. Additionally, the publication features a report on the application of adverse inference in tax disputes.

Bennett Jones on Tax Disputes February 2023

Bennett Jones on Tax Disputes - February 2023

The 14th edition of Bennett Jones on Tax Disputes, published on <a rel="noopener noreferrer" href="https://www.gettaxnetpro.com/" target="_blank">Taxnet Pro</a> by Thomson Reuters, includes articles on (1) the impact of case law in the area of document disclosure related to policy relied upon by the Minister of National Revenue in raising an assessment pursuant to the general anti avoidance rule and (2) Rule 58 of the Tax Court of Canada Rules (General Procedure) and the pronouncements made by the Federal Court of Appeal in its recent decisions, including 632738 Alberta Ltd. v Canada 2021 FCA 43. The publication also has summaries of recent tax decisions, tables regarding tax appeals, the CRA business continuity plans and bulletins/practice directives from the courts.

Bennett Jones on Tax Disputes May 2021

Bennett Jones on Tax Disputes - May 2021

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

Vincent M. de Grandpré

IP Lawyer | Life Sciences & Tech

Melissa M. Dimilta

Intellectual Property Lawyer at Bennett Jones Toronto

Partner, Trademark Agent

As part of a deeply interconnected global sector, the life sciences industry in Canada is undergoing significant change alongside broad macroeconomic and geopolitical shifts.&nbsp;The Bennett Jones Life Sciences team looks at the top issues and developments affecting the industry in 2026.

2026 Life Sciences outlook

Legal and Market Trends to Watch This Year

Life Sciences Outlook 2026

Emily P. Kettel

Cross-border collaborations are central to the life sciences industry, but they can also raise complex questions about patent infringement liability in Canada. This update examines the Federal Court&rsquo;s recent decision in Adeia Guides Inc v Videotron Ltd and its implications for companies involved in the development, supply and commercialization of patented products and services. The authors explore how Canadian law approaches common design infringement, experimental use exemptions and the potential liability of foreign partners whose activities contribute to products ultimately sold in Canada.

Life Sciences Collaborations and the Risk of Joint Patent Infringement

Aaron E. Sonshine

Corporate Finance, Mergers and Acquisitions and Corporate Governance Lawyer at Bennett Jones Toronto

Partner 

The life sciences sector is experiencing a renewed wave of M&amp;A activity driven by patent expiries, expanding investor appetite and growing demand for innovative therapies and technologies. Drawing on insights shared at the Bloom Burton &amp; Co. Healthcare Investor Conference, this update explores the key trends shaping dealmaking in Canada and globally, including increased competition for assets, rising private transactions and growing investment in emerging markets such as China. The author also examines why current market conditions point to continued momentum across the sector in the second half of 2026.

Large Corporation Objection and Appeal Process: What's Wrong with This Picture"

From the Same Authors