Transfer Pricing Advisers
100 Queen StreetSuite 800Ottawa K1P 5T8Canada
Tel: (1) 613 751 5293
Shiraj Keshvani is a partner in Deloitte's global transfer pricing and tax controversy practice. Shiraj holds BA and MA degrees in Economics and, before joining Deloitte, was the chief economist for the Canada Revenue Agency's (CRA) 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.
With 15 years' service with the CRA, primarily in the area of international taxation and transfer pricing, Shiraj first served with the assistant deputy minister of the Verification, Enforcement and Compliance Research Branch. Since then, he has held progressively more senior positions in the Compliance Research Directorate, the Assistant Commissioner's Office of the Compliance Programs Branch, and the International and Large Business Directorate. In 1999, he joined the International Tax Division as a transfer pricing economist where he was involved in providing support to the field in the course of transfer pricing audits. He was subsequently appointed to the position of senior transfer pricing economist, and in May 2007 began serving, on an interim basis, as the APA coordinator and chief economist before being permanently appointed to that position.
As the APA coordinator and chief economist, Shiraj took a leadership role in setting priorities, establishing policies, and issuing guidance for Canada's APA programme. He was also a member of the Transfer Pricing Review Committee, which considers taxpayers' compliance with Canadian legislation. On the global front, he was involved in developing Canada's position on international initiatives such as the OECD's work on the taxation of multinational enterprises and, having spent the greater portion of his career with competent authority, gained significant experience reconciling Canadian views on transfer pricing with that of other countries to resolve double tax. More recently, as part of the management team and having responsibility for policy and procedures for the advance pricing arrangement programme, 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. Within the CRA, Shiraj developed and delivered a number of training initiatives to personnel in the field and has on a number of occasions been involved in facilitating the resolution of highly complex or controversial audits.
Since joining Deloitte, Shiraj has assisted multinationals and other clients in managing and resolving difficult and contentious tax controversy issues. He has also conducted a number of 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. He continues to remain active on the policy front and is a member of the Business and Industry Advisory Committee (BIAC) Tax Committee (the BIAC to the OECD) and the International Chamber of Commerce Commission on Taxation.
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