Shiraj is a Tax partner in PwC’s transfer pricing practice.
Having worked in both the public service and public practice, Shiraj has nearly 20 years of experience in transfer pricing. Since joining public practice, Shiraj has assisted multinationals and other clients in across a variety of industry sectors including Energy, Resources, TMT, Automotive, Services and Pharmaceutical to manage and resolve difficult and contentious tax controversy issues.
He has conducted a number of transfer pricing projects in a variety of industries involving audit defense, competent authority assistance, advance pricing arrangements (APAs) as well as planning and preparing documentation. These projects have addressed a wide range of transfer pricing issues including financing, business restructurings, pricing of intangible assets and tangible flows, the allocation of intra-group service charges, the treatment of technology and process solutions as well as location rents and saving. He has also assisted with due diligence in support of deals where he has been asked to help reconcile differing views.
Prior to joining public practice, Shiraj spent nearly 15 years with the Canada Revenue Agency (CRA). Prior to leaving the Public Service, Shiraj was the Chief Economist for CRA's Competent Authority Services Division and the national APA Coordinator. During this time, Shiraj was also a member of the Transfer Pricing Review Committee, which considers taxpayers' compliance with the Canadian legislation, was involved in developing Canada's position on international initiatives, was actively involved in negotiating the mode of application for the arbitration provisions under the 5th protocol to the Canada-US Treaty. He 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 continues to remain active on the policy.
Transfer pricing, dispute Resolution
Automotive, energy, natural resources, oil and gas, pharma, tech and telecoms
