About Pierre G. Alary

Transfer pricing, tax disputes and international tax are the core of Pierre G. Alary's work. Alary is a partner with Gowling WLG in Ottawa, serves as the firm's National Co-Leader for Transfer Pricing & Tax Dispute Resolution, and sits on its Transfer Pricing and Competent Authority Group.

When the Canada Revenue Agency comes calling, Alary steps in at both the audit and the appeal stage, on domestic questions as well as cross-border ones. The international side covers things like residence, permanent establishments, withholding tax, e-commerce and employees working across borders. A lot of the work is forward-looking, too: Alary secures Advance Pricing Arrangements that cover future tax years, helps clients resolve Mutual Agreement Procedure cases, and prepares contemporaneous transfer pricing documentation.

Called to the Ontario bar in 2010, Alary earned an LLB cum laude from the University of Ottawa the year before. Clients can work with Alary in French or English.

Alary's writing has run in a long list of tax journals, among them Practical International Tax Strategies, the Transfer Pricing International Journal and The International Tax Review, and it was cited in the 2022 Practitioner's Income Tax Act. Accountants may also know Alary from CPA Canada's course on managing transfer pricing.

Practice areas

Transfer pricing and competent authority

Alary helps clients put Advance Pricing Arrangements in place for future tax years, works through Mutual Agreement Procedure cases, and prepares contemporaneous transfer pricing documentation.

CRA audits and appeals

Representation at the audit and appeal stages of disputes with the Canada Revenue Agency, on domestic and international issues alike.

International tax

Cross-border questions such as residence, permanent establishments, withholding tax, e-commerce and employees who work across borders.

Education & credentials

  • LLB (cum laude), University of Ottawa (2009)
  • Called to the bar, Ontario (2010)

Publications & speaking

  • Managing Transfer Pricing, CPA Canada
  • When to File (and When to Not File) a Service Complaint against the CRA, Gowling WLG (2021)
  • Canada's APA Program: An Overview, Gowling WLG (with Dale Hill and Andre Bergeron) (2021)
  • Resolving Transfer Pricing Disputes in Canada, with Dale Hill (2014)
  • Canada and U.S. Announce Agreement regarding PE Attribution of Income Principles under Canada-U.S. Treaty, Bloomberg BNA Transfer Pricing International Journal (with Jim Wilson) (2013)

Memberships & affiliations

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This listing was generated by AI from public sources in October 2026. It may contain errors, and we can’t guarantee it’s accurate or complete. Before you rely on anything here, verify it on their firm’s website. Confirm Pierre G. Alary’s licence and standing in the Law Society of Ontario directory ↗

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