Christopher (Chris) S. Raybould is the Canadian Transfer Pricing Practice Leader and Director of Economics for Baker McKenzie in Toronto and previously served as a member of the firm’s North American Transfer Pricing Steering Committee.
Mr. Raybould handles transfer pricing advisory work in various capacities. He advises on and assists in negotiating advance pricing arrangements, pursuing competent authority assistance, provides audit defense representation, appeals support, and Transfer Pricing Review Committee representation. He also advises on a variety of other types of transfer pricing projects, including BEPS related advice, risk identification and assessment, planning and compliance studies, and assists with the transfer pricing aspects of business conversions and restructurings, acquisition due diligence and integration.
Mr. Raybould has extensive experience in a number of industry sectors including automotive, pharmaceutical, food, financial investments and products, manufacturing, consumer businesses, technology, and commodity-based businesses. Mr. Raybould is an author on transfer pricing issues and a frequent speaker.
Mr. Raybould's clients include Canadian companies and subsidiaries of foreign companies in various industries, including manufacturing, automotive, consumer, oil and gas, forestry and technology industries. He routinely assists in various financial transactions, transfers of tangible goods, provision of services, licensing of technology and franchising, to complex restructurings and redesigns of businesses.
Representative Legal Matters
Advised on the implementation and review of a corporate restructuring for a company in the forestry industry.
Advised on APAs and competent authority settlements for Canadian subsidiaries of U.S. Tier I auto parts suppliers converting from a licensed, fully-fledged manufacturer to contract manufacturers.
Developed a transfer pricing model and policy for a major software company and then prepared the relevant documentation.
Represented the Canadian subsidiary of a major European manufacturer in a provincial transfer pricing appeal pertaining to intra-group services.
Advised the Canadian subsidiary of a major U.S. transportation service company in dealing with a CRA audit involving intra-group service charges.
- Advised a U.S. headquartered consumer goods company with a Canadian subsidiary related to the use of internal versus external comparables during a CRA audit and related to representations to the Transfer Pricing Review Committee.
- CFA Institute (Chartered Financial Analyst® designation) (2002)
- Queen's University (Master of Arts Economics) (1999)
- Queen's University (B.A.H.) (1997)