Kaitlin Gray

Kaitlin’s advisory practice focuses on transfer pricing, international tax and dispute resolution.

In her transfer pricing practice, Kaitlin has experience developing transfer pricing policies, managing complex audits, and handling tax litigation and competent authority applications for companies with cross border business operations. Kaitlin also has expertise in other areas of international tax, such as the implementation of the global minimum tax in Canada and the hybrid mismatch rules.

Kaitlin has broad-based experience in the resolution of tax disputes relating to transfer pricing and international tax as well as other tax issues such as tax avoidance, the deductibility of expenses and resource taxation matters. Kaitlin has appeared before the Tax Court of Canada and the Federal Court of Appeal in disputes with the Canadian tax authorities.

Kaitlin was previously seconded to the Department of Finance Canada where she worked on legislation relating to international outbound matters.

Representative Work

  • Suncor Energy Inc.

    Suncor Energy Inc. in its takeover of day-to-day operations at Syncrude oil sands mining joint venture

  • Wheaton Precious Metals in the successful resolution of its transfer pricing appeal to the Tax Court
  • A royalty and streaming company in its pending transfer pricing appeal to the Tax Court
  • Various Mutual Agreement Procedure (MAP) matters for relief from double taxation
  • Various Advanced Pricing Arrangement (APA) matters regarding, among other things, global cost sharing arrangements
  • A pipeline company in the successful resolution of its dispute with CRA regarding transaction costs

Latest Insights

  • Osler Update May 2, 2024

    Canadian government moves ahead with Global Minimum Tax Act

    Canada’s Pillar Two legislation, the Global Minimum Tax Act, is introduced in Parliament. In their Update, Patrick Marley, Oleg Chayka, Ilana Ludwin a...

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    Canadian government moves ahead with Global Minimum Tax Act
  • Osler Update Apr 30, 2024

    Transfer Pricing 2024: Law and Practice

    The federal government has plans to update the rules that govern transfer pricing — the pricing one branch or division or group of a company charges a...

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    Transfer Pricing 2024: Law and Practice
  • Osler Update Feb 28, 2024

    CRA releases revised APA guidance

    The CRA revised its guidance on Advance Pricing Arrangements, introducing significant updates to criteria for acceptance into the program. The release...

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    CRA releases revised APA guidance
  • Osler Update Dec 11, 2023

    Transfer pricing proposals infuse Canada’s tax laws with OECD concepts

    Canada’s transfer pricing rules ensure that, for Canadian income tax purposes, the pricing of non-arm’s length cross-border transactions adheres to th...

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    Transfer pricing proposals infuse Canada’s tax laws with OECD concepts
View all Insights

Awards and Recognition

  • Best Lawyers: Recognized as “One to Watch” in Tax Law
  • Completion of the CPA In-Depth Tax Course and CPA In-Depth Transfer Pricing Course

Community Involvement

  • Tax Court Assistance Project

Speaking and Writing

Speaking Engagements

speaker 14/5/2024
2024 IFA Canada Tax Conference
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2024 IFA Canada Tax Conference
Speaker, ‘Hybrid Mismatch Rules: What’s Cooking?’, Montreal , May 14, 2024 – May 15, 2024

2023 CPTS Annual Conference
Speaker, ‘Transfer Pricing Dispute Trends and Issues’, June 6, 2024 (with Amanda Heale)

2021 CPTS Annual Conference
Speaker, ‘Current Cases’, June 1, 2021 (with Joanne Vandale)

2018 CPTS Fall Lecture Series
Speaker, ‘Managing Transfer Pricing Audits and Disputes Pre-Litigation’, October 3, 2018 (with Amanda Heale)

Published Work

“Proposed Changes to Canada’s Transfer Pricing Rules” Tax Litigation Journal, Volume XXVI, No. 3, 2023

“Transfer Pricing 2024 – Canada”, Global Practice Guides, Chambers and Partners, April 11, 2024 (with Edward Rowe, Mark Brender and Amanda Heale).

“Finance Proposes Tying Transfer-Pricing Rules to OECD Guidelines” Canadian Tax Focus, 13:3, August 2023

TPM-02R: Transfer-Pricing Secondary Adjustments and RepatriationCanadian Tax Focus, 11:1, August 2021



  • University of Calgary, J.D.
  • University of British Columbia, Bachelor of Kinesiology


  • English

Professional Affiliations

  • International Fiscal Association
  • Canadian Tax Foundation
  • Canadian Petroleum Tax Society
  • Law Society of Alberta