US hardware manufacturer imported finished goods into China at a transfer pricing that left China with a small profit. When the Chinese customs authority challenged the per unit pricing reported claiming it should be higher, CRA’s transfer pricing group provided both external per unit pricing support as well as the economic reality of increasing pricing leaving the China entity at a loss and its impact on corporate taxation overall.
Highlights from 2025 and looking forward to 2026
In the United States, 2025 brought major activity in high profile transfer pricing disputes and reaffirmed how closely transfer pricing, tariffs, and customs...