David Canale
We live in an interconnected world where information given to one tax jurisdiction can easily be availed by others. And the actions of MNCs in one country could impact their situation in another.

David Canale

Former EY Global Transfer Pricing Controversy Services Leader

Outside-the-box thinker in resolving transfer pricing controversies. Creative and technical, yet practical. Love the outdoors. Husband. Father.

Areas of focus Tax Risk

As the Former EY Global Transfer Pricing Controversy Services Leader, David has advised multinational companies on transfer pricing controversy, risk management, planning and structuring in the past.

With 23 years of industry experience, he has assisted clients with transfer pricing policies, controversy resolution, advance pricing agreements (APAs) and mutual agreement procedures. He also focused on the implementation of the Organisation for Economic Co-operation and Development’s action plan on base erosion and profit shifting.

Prior to joining EY, he served with the Internal Revenue Service’s APA Program in the Office of Associate Chief Counsel (International). He also served as Chair of Transfer Pricing Committee in the American Bar Association’s Section of Taxation and is a technical reviewer on government submissions on behalf of the Section.

David earned his JD from American University Washington College of Law and his LLM in Taxation from Georgetown University Law Center. 

How David is building a better working world

“My work with clients requires me to develop customized technical, yet practical, approaches to manage risk and resolve complex transfer pricing issues where one or more tax authorities are looking to increase revenue in their countries. I team with clients and work closely with tax authorities to build the trust required for the long-term client and tax authority relationships needed to smoothly operate in such countries. Such multi-sided resolutions enhance clients’ reputations as good corporate citizens, establishing a win-win result for the clients as well as the tax authorities.”

Contact David