Arcotia Hatsidimitris - International Tax Dialogue

66 – 7. RESOURCES, SKILLS AND USE OF SPECIALISTS
Box 18. Canada
Canada’s experience is different:
Canada is one of a number of countries that did not make routine use of economists but is now
increasing the number of economists it employs.
The CRA currently has 20 economists in the International Tax Division and about 12 economists work for
the Competent Authority. The 20 economists are embedded in the International Audit Team and work
alongside auditors. As a result they travel around Canada a good deal. CRA has a university recruitment
program for those with a Master’s degree or PhD and they receive further training and have a specific career
track. Auditors in the field value the services provided by economists in transfer pricing cases. CRA has found
it is useful to involve economists in the initial risk assessment process and in the appeals function.
Overall it is clear that transfer pricing is a specialised subject and, while organisational models
vary between tax administrations for good reasons, they all need to address the need to build up the
necessary expertise and experience of managing transfer pricing issues. Knowledge management,
which seems to go hand in hand with good governance, plays an important part in improving the
quality and consistency of transfer pricing settlements. The organisation of the work should also help
to develop a good working relationship between specialists and general auditors working on the case.
Tax administrations have also found external specialists to be of value but they need to look for
opportunities to secure knowledge transfer from those specialists where they can and have to manage
the costs involved with some care.
Key thoughts for the chapter
Many tax administrations face a constant challenge in maintaining sufficient expertise in their
organisation to tackle the toughest transfer pricing cases. Improving knowledge management and
training are essential to meeting this challenge. For some tax administrations that is best done through
the use of large, mixed teams whose members develop complementary skills and experience. Others
maintain a core team of specialists who support colleagues in front line units. External specialists also
have an important part to play in supporting the transfer pricing work of tax administrations.
DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012