"Transfer Pricing"

Transfer Pricing

CRA offers comprehensive, superior transfer pricing services to companies in all industries worldwide. Our experts provide practical, independent that helps our clients use transfer pricing as a strategic tool to enhance competiveness and enterprise value. CRA has been involved in complex assignments with pivotal and high-stakes outcomes for more than 20 years.


CRA has prepared foreign documentation for tax authorities in Australia, Austria, Canada, France, Germany, India, Israel, Japan, Mexico, the Netherlands, Poland, the United Kingdom, the United States, and other countries. Our documentation helps multinational companies mitigate their audit risk and defend their transfer pricing policy when audits occur. CRA has prepared transfer pricing documentation that has satisfied Internal Revenue Code (IRC) Section 6662(e) and met the requirements of revenue agencies across the globe, and our have prepared documentation studies associated with in-bound and out-bound tangible and intangible goods transactions, intercompany service transactions, cost-sharing arrangements, and intercompany loan transactions.


CRA helps companies reduce risk and develop creative yet sound transfer pricing planning strategies and practical transfer pricing policies that respect the arm’s length standard.

CRA provides transfer pricing advice during all types of planning arrangements, including planning for and negotiating advance pricing agreements (APAs), pricing intangible assets transferred during a business restructuring, implementing royalties for new intangible holding companies, and restructuring the allocation of risks (and associated transfer prices) between related companies. Clients in the consumer products, pharmaceutical, and technology industries have also relied on our planning advice in the areas of trademarks and marketing intangibles. We have also been called upon to provide objective assessments of strategies developed by other firms.

Advance pricing agreements (APAs)

CRA provides clients with the transfer pricing and economic expertise needed to negotiate favorable APAs. We assist in all stages of the process, from determining whether an APA would benefit a company’s tax position to recommending a transfer pricing methodology. We also prepare an initial APA request and support economic analyses to negotiate with tax authorities on a company’s behalf as well as prepare annual documentation of compliance with the APA and assist with renewal strategy.

Our transfer pricing professionals have structured and negotiated numerous unilateral and bilateral APAs. These have included inbound and outbound transactions of tangible and intangible products across a number of industries and countries, including Canada, Japan, Germany, and Australia.

Tax valuation

CRA has extensive experience advising multinational clients on the value of their intellectual property, technology, trade names, and other intangible assets during transfer pricing proceedings. Our experts have provided expert witness testimony before the US Tax Court, and they possess the experience and judgment needed to tailor economic and financial models based on the unique facts and circumstances of each case.


From planning a new transfer pricing structure to testifying as experts in US or foreign courts, CRA provides comprehensive audit and litigation support services during transfer pricing controversy. We have supported clients under audit by tax authorities in Japan, Canada, Italy, France, Germany, the United Kingdom, Singapore, Hong Kong, Malaysia, Australia, and the Netherlands. We have also advised clients engaged in competent-authority proceedings in Germany, Spain, Switzerland, and Japan.

FIN 48

CRA has prepared FIN 48 analyses for a number of multinational companies. Our analyses draw on our vast experience in audit and controversy work involving tax authorities across the globe and our ability to apply sound economic analysis to value the tax result associated with alternative tax positions in a manner that is likely to prevail in controversy, either at the local or competent authority level.

Regulation and BEPS

As a member of the Business and Industry Advisory Committee to the OECD, CRA is directly involved in the significant revisions to transfer pricing guidelines that the OECD plans to finalize in 2015, as mandated by the G20-OECD action plan on BEPS (Base Erosion and Profit Shifting).

Industry expertise

Our transfer pricing team is supported by a broad spectrum of resources, enabling us to leverage key skills and deep industry knowledge to the benefit of our clients. Together, our consultants offer world-class expertise in multiple disciplines and industries, including, but not limited to, airline, automobile, banking, computer hardware and software, consumer products, durable products, credit card and credit card security, energy, health care, heavy manufacturing, pharmaceuticals, retail, real estate, telecommunications, and various utilities.