Dale C. Hill

About Dale C. Hill

Dale C. Hill helps multinational companies head off and settle transfer pricing disputes with tax authorities. Audit defence and dispute resolution are the heart of the work, and Dale has helped keep tax authorities in North America, Europe and Asia from imposing costly adjustments and penalties on some very large multinationals.

It's a practice built on years spent on the government's side. Dale joined Gowling WLG in 2005 after 16 years at the Canada Revenue Agency in international transfer pricing and tax avoidance, a stretch that included the early days of the APA program in the 1990s. As a senior manager in the CRA's International Tax Directorate, Dale took part in over 40 Advanced Pricing Agreements with many countries and hundreds of Competent Authority requests. In 2004 Dale led the creation of a national field strategy that set out how the agency's Competent Authority, tax services offices, appeals and head office would work together on audit adjustments, both those raised in Canada and those begun by foreign governments.

In 2019 Dale called the Tax Court of Canada's Cameco decision a clear win for traditional tax planning in an interview with Law Times. In 2022, commenting to CBC News on a contested CRA arrangement with a large company, Dale saw no sign of a sweetheart deal.

Dale has a good deal of experience with Asian governments and businesses, and helps major Asian clients of the firm get the most from their worldwide operations on the transfer pricing side. Client work runs across a range of industries, from pharmaceuticals and auto to computer software. Government bodies in India and Singapore, along with industry groups at home and abroad, regularly invite Dale to lead seminars on transfer pricing, and Dale has presented through the Canadian Tax Foundation, Infonex and the Tax Executive Institute, among others. In Ottawa, Dale is a partner on Gowling WLG's Transfer Pricing and Competent Authority Team and works hand in hand with the firm's National Tax Practice Group.