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Fabio Bojorquez

Fabio Bojorquez

Senior Manager, PwC Canada

Fabio is an economist with 12 years of experience in Transfer Pricing who joined PwC Montreal’s Transfer Pricing group in May 2017. Fabio has worked on a wide range of transfer-pricing related issues in Canada and in the US, including documentation, planning, valuation, Advance Pricing Agreements and controversy work.

Fabio has participated in numerous transfer pricing planning and documentation projects to determine proper arm’s-length compensation for tangible property, intangible property, financial transactions and services.

He has performed transfer pricing studies mostly in connection with Canadian, US and Latin-American documentation requirements for clients in the aerospace transportation, dairy, metals & mining, financial services, pharmaceuticals, software, consumer products, consumer electronics, and textile industries.

Because of his technical training, Fabio’s focus transitioned into more complex transactions over the years. His tenure in the New City office of a Big Four greatly contributed to consolidate his expertise on new and more complex transfer pricing issues.

Fabio was also involved in Advance Pricing Agreement (APA) projects and transfer pricing audit defense engagements for multinational clients. Notably, Fabio was part of the team that successfully obtained the first Canadian APA in the pharmaceutical industry and, years after, he formed part of the team negotiating the first Canadian APA in relation to a financial transaction. Fabio worked in other APAs projects during his years in Montreal and also during his secondment in New York City.

Experience

  • Financial Transactions
  • Valuation for TP Purposes
  • Documentation
  • Audit Defence
  • Competent Authority

Specialty

  • Transfer Pricing Planning
  • Tax Controversy

Education

  • MA - Economics
  • University of Montreal (2006)
  • BA - Economics & Politics
  • University of Montreal (2005)
  • MBA courses
  • Universidad Politécnica de Madrid (1999-2001)
  • Chemical and Metallurgical Operations
  • TECSUP Institute
  • Lima - Peru (1997)