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Partner, Tax Dispute Resolution (TDR) Transfer Pricing Leader, PwC Canada
Shiraj Keshvani is a tax partner in PwC’s transfer pricing practice.
Shiraj assists multinationals and other clients to manage and resolve difficult and contentious tax controversy issues. He has also conducted a number transfer pricing projects, in a variety of industries, involving audit defence, competent authority assistance, APAs, as well as planning and documentation studies. These have addressed a wide range of transfer pricing issues including business restructurings and the treatment of intangibles.
Shiraj has 15 years of experience working for the Canada Revenue Agency (CRA) where he held the positions of Chief Economist for the Competent Authority Services Division and the national APA Coordinator. He has a deep understanding of CRA's policies and procedures and the CRA perspective and focus on many contentious issues.
As the APA Coordinator and Chief Economist, Shiraj took a leadership role in setting priorities, establishing policies and issuing guidance for Canada's APA program. Shiraj was also a member of the Transfer Pricing Review Committee, which considers taxpayers' compliance with the Canadian legislation. On the global front, Shiraj was involved in developing Canada's position on international initiatives such as the OECD's work on the taxation of multinational enterprises and gained significant experience reconciling Canadian views on transfer pricing with that of other countries to resolve double tax. As part of the management team and having responsibility for policy and procedures for the Advance Pricing Arrangement Program, he was actively involved in negotiating the mode of application for the arbitration provisions under the 5th protocol to the Canada-US Treaty. Shiraj was also one of a few individuals working with the Advisory Panel on Canada's System of International Tax on specific transfer pricing and competent authority issues.
Shiraj holds Bachelors (honours) and Masters of Arts degrees in Economics and continues to remain active on the policy front and is currently a member BIAC Tax Committee (The Business and Industry Advisory Committee to the OECD) and the ICC (International Chamber of Commerce) Commission on Taxation.