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.
Global updates on transfer pricing guidance
Over the past several months, tax authorities worldwide and the OECD have issued significant updates to transfer pricing regulations, guidance, and compliance...