Jasen Spry

Jasen is a Transfer Pricing Partner at PwC Canada with more than 25 years of technical experience gained at the Canada Revenue Agency (CRA), including 15 years specializing in transfer pricing within the Competent Authority Services Division (CASD), the International Tax Division (ITD) and the Appeals Branch.

During his time at the CRA, Jasen developed extensive knowledge of dispute resolution processes, audit methodologies and risk assessment protocols. This regulatory perspective provides valuable insight to corporate clients navigating an increasingly stringent global environment. He has managed bilateral and multilateral Advance Pricing Arrangements (APAs), Mutual Agreement Procedures (MAPs), Notices of Objection (NOOs) and Notices of Appeal (NOAs), resolving complex cross-border controversies and helping multinational enterprises prevent double taxation. Jasen has also gained additional perspectives through his participation in several committees, including the Transfer Pricing Review Committee (TPRC) and the MAP-APA Review Committee (MARC).

At PwC, Jasen draws on his agency-side experience to develop robust and proactive transfer pricing controversy and planning strategies. Known for his pragmatic and collaborative approach, he helps bridge the gap between tax policy objectives and practical business implementation. His background enables him to design sustainable, audit-ready transfer pricing structures aligned with Canadian and international guidelines, including OECD frameworks. His transition to PwC combines regulatory insight with professional services capabilities and reinforces the firm’s position as an advisor in international taxation.

Jasen has worked on transfer pricing matters across a broad range of industries, including pharmaceuticals, mining, technology, manufacturing, professional services, natural resources, retail, oil and gas, banking, insurance and aluminium. His experience also includes transfer pricing matters involving debt financing.

He served as the Competent Authority Services Division coordinator for Germany for more than seven years and negotiated cases with competent authorities in the United States, Germany, the Netherlands, Spain, Norway and Chile. Jasen has also appeared on behalf of the Crown in several proceedings before the Tax Court of Canada, including settlement conferences before various judges.