People

Services

Industries

Firm

About

Knowledge

Careers

News

Events

Contact

Connect

Privacy Policy

Manage Cookies

Disclaimer

Terms of Use

Accessibility

Payments

Legal

Calgary

Toronto

Edmonton

Ottawa

Vancouver

New York

Montréal

Jehad Haymour

Vice Chair, Tax Litigation and Dispute Resolution Practice Group

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

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

Kristopher R. Hanc

M&A and Capital Markets Lawyer

Christopher J. Doucet

Corporate & Mining Lawyer | M&A & Corporate Finance

Aidyn Bhatia

Lawyer at Bennett Jones Toronto

The Canadian Securities Administrators (CSA) has launched a broad consultation on modernizing the regulation of public companies, examining venture issuer status, financial reporting, resale restrictions, material change reporting and alignment with U.S. developments. The Consultation Paper includes a proposed qualified institutional purchaser exemption that could provide eligible reporting issuers with greater flexibility to raise capital without traditional resale hold periods. Stakeholders have until November 13, 2026, to submit comments.

CSA Publishes Sweeping Consultation on Modernizing the Regulation of Public Companies

Meg Tweedlie

Director, Student Talent

Samuel Judson

Commercial Real Estate Lawyer at Bennett Jones Toronto

Change of control provisions in commercial leases can create uncertainty for both landlords and tenants, particularly where terms such as &ldquo;control&rdquo; and &ldquo;effective control&rdquo; are undefined. This article examines the Canadian legal landscape, key case law and Section 23 of Ontario&rsquo;s Commercial Tenancies Act, and offers practical considerations for drafting and negotiating change of control provisions. It also highlights potential carve-outs and strategies to reduce ambiguity and the risk of future disputes.

change of Control of Commercial Tenants Drafting

Change of Control of Commercial Tenants: Drafting, Interpretation and Practical Considerations

Akhila Sandhu

Summer Student

Morgan Sutherland

Associate 

Michael C. Smith

Litigation Lawyer at Bennett Jones Toronto

The United Nations has adopted the first global regulatory framework for Automated Driving Systems, establishing safety, cybersecurity, testing and monitoring requirements for Level 3, 4 and 5 automated vehicles. This article examines the framework&rsquo;s implications for Canada, including how Transport Canada may incorporate the requirements into domestic vehicle safety standards and what manufacturers and suppliers should consider as regulation evolves.

First Global Regulatory Framework For Autonomous Vehicles

First Global Regulatory Framework For Autonomous Vehicles: Key Takeaways For Canada And The Auto Industry

Martin Ignasiak KC

Energy & Industrial Projects Lawyer

Head of Energy Regulatory

Michael P. Theroux KC

Commercial Litigation, Arbitration & Energy Litigation Lawyer

Partner 

Brynne Harding

Litigation Lawyer at Bennett Jones Calgary

The Supreme Court of Canada has resolved one of the most consequential questions left open by Vavilov, and which has divided jurisprudence in lower courts since then&mdash;whether judicial review is constitutionally guaranteed or can be barred by privative clauses.

Big Implications for Appeals from Administrative Tribunals

The Supreme Court Settles the Constitutional Floor for Judicial Review in Democracy Watch v Canada

Ethan Z. Schiff

Class Actions & Commercial Litigation Lawyer

Jenna Vivian

Commercial Litigation Lawyer at Bennett Jones Edmonton

The Supreme Court of Canada&rsquo;s decision in SS&amp;C Technologies Canada Corporation v. Bank of New York Mellon Corporation, 2026 SCC 29, revisits the doctrine of spoliation and confirms that courts must draw an adverse inference when intentional destruction of relevant evidence is established. The decision provides guidance on the test for spoliation, the scope of mandatory adverse inferences and the importance of preserving evidence during litigation.

The Supreme Court of Canada Affirms Mandatory Adverse Inference in Cases of Spoliation

The Supreme Court of Canada Affirms Mandatory Adverse Inference for Spoliation

Title Alphabetical

Title

normal

Canadian Association of Petroleum Producers Tax Roundtable 2015

From the Same Authors