Sébastien Rheault

Sébastien Rheault


T 514 982-6148


Sébastien Rheault (LL.L., cum laude, Dean’s List; MBA; Ontario and Quebec Bar Associations) is a partner at Barsalou Lawson Rheault LLP. With over 20 years’ experience in transfer pricing and tax controversy (Highly Regarded ranked in Euromoney and International Tax Review), Sébastien primarily represents multinational corporations in audits, before the Appeals Branch, at the competent authority level (MAP/APA) as well as before federal (Tax Court of Canada, Federal Court, Federal Court of Appeal) and provincial courts.

Sébastien also advises on various corporate tax matters, including transfer pricing, tax incentives (SR&ED credits, e-business), non-resident trust rules, Canadian income tax conventions, the General Anti-Avoidance Rule (GAAR), corporate restructurings as well as mergers and acquisitions.

He served as a Governor of the Canadian Tax Foundation (2015-2018) and as President of the Canadian Bar Association’s Tax Section (Quebec Division). At the invitation of the Organisation for Economic Co-operation and Development (OECD), he has presented various consultations on tax Base Erosion and Profit Shifting (BEPS).

Sébastien participates and contributes to endurance cycling events supporting high-level student-athletes in Canada (Fondation Aléo).

Conferences and Publications

CTF – Annual Conference
Speaker: “Economic substance in transfer pricing and GAAR”
Montreal, November 2023

Cambridge Forum on Transfer Pricing Law
Washington DC, October 2023
“Introduction to International Taxation in Canada”, 6th edition, Thomson Reuters (co-author/ collaboration – Centralized Cash Management Agreements ʺCash Poolingʺ), 2019-2024 Editions

NABE – Annual Transfer Pricing Symposium
Speaker: “The Berry Ratio in transfer pricing’’
Washington DC, July 2023

Cambridge – International Forum on Transfer Pricing Law
Surrey, England, October 2022

NABE – Annual Transfer Pricing Symposium (TPS)
July 2022

CTF – Transfer Pricing Conference
May 2022

TP MINDS – Transfer Pricing Professionals in The Americas
February 2022

Cambridge – Annual Tax Conference: International Forum on Transfer Pricing Law
January 2022

CTF – Annual Tax Conference
November 2021

APFF – Annual Congress
September 2021

IFA – International Tax Conference
May 2021

CTF – Transfer Pricing Conference with the CRA and OECD
February 2021

APFF – Annual Congress
October 2020

IFA – International Conference
May 2020

TEI (Tax Executives Institute) – Tax Controversy Seminar, Morgan Lewis
Exchange of Information: Issues, Use and Collaboration, 2019
Life Sciences Law in Canada, 2nd Edition (Chapter on tax aspects including transfer pricing and tax incentives), 2019
“Introduction to International Tax in Canada”, 6th edition, Thomson Reuters
(co-author/collaboration – Cash Pooling Arrangements), 2019
Transfer Pricing: Review of Canadian caselaw and pending cases, 2019
Los Angeles, February 2020

IFA – National Tax Conference
Co-panelist with Canada Revenue Agency on International Exchanges of Information
Montreal, May 2019

TEI – Annual National Tax Conference
Co-panelist on Canada Revenue Agency access to tax provisions and related matters
Ottawa, May 2019

CTF – Transfer Pricing Conference with the Canada Revenue Agency and OECD
Toronto, March 2019

APFF – Transfer Pricing Panel with the Canada Revenue Agency (ITD) and OECD
October 2018

TEI – National Conference on Transfer Pricing and BEPS under Canadian law
Ottawa, May 2018

APFF – International Tax & Transfer Pricing Panel with the Canada Revenue Agency and OECD
October 2017

CTF – Voluntary Disclosure Programs in Canada, Quebec and U.S.
September 2017

CTF – Legal Implementation of BEPS in Canada
July 2017

APFF – Quebec Revenue Congress on Fiscal Advantages: Symposium Tax credits in SR&ED
Tremblant 2015 and Esterel, 2016

Global Transfer Pricing Conference
“BEPS Driven Controversy”, Bloomberg BNA / Baker McKenzie
Toronto, October 2015

APFF – Annual Tax Conference: Transfer Pricing and International Tax Panel
2014 and 2015

ACC (Association of Corporate Counsels) – Transfer Pricing and Other Current Tax Issues for Corporations: Seminar on managing corporate tax risks
Montreal, March 2015

AMBAQ – “Tax Credits in the Gaming Industry”
MBA Magazine – MBA Association of Quebec
Quebec, January 1st, 2015

CPA Canada – Canadian Institute of Chartered Accountants: SR&ED Tax Credits Symposium, Documenting & Defending SR&ED Claims
Toronto, 2015

CTF – Technical Seminar on Transfer Pricing
Co-speaker with Sue Murray, Director at Competent Authority (CRA)
Montreal, February 20, 2014 and Ottawa, May 28, 2014

CTF – LexisNexis lui a attribué la mention « Distinction » selon une évaluation par ses pairs en fiscalité

CTF – Annual Conference on Report of Proceedings of the 63rd Tax Conference on Recharacterization of Transactions in Transfer Pricing Audits & Appeals


Canadian Bar Association, Tax Section – Québec Division (CBA)
President, Tax Section, 2010-2012
Member and President, Tax Section, 2013-2019

Canadian Tax Foundation (CTF)
Member, Board of Governors, 2015-2019

Association de Planification Fiscale et Financière (APFF) (Quebec Tax Association)
Member of the Organizing Committee of the Annual Tax Conferences, 2015 and 2019

International Fiscal Association (IFA)

MBA Association of Quebec (AMBAQ)

Association of Corporate Counsel (ACC)



2000 McGill College Avenue
Suite 1500
Montréal (Québec)
Canada H3A 3H3

T 514 982-3355
T 416 777-9380
F 514 982-2550