A multinational life sciences company recognized that they were exposed to VAT leakage due to costs not being allocated appropriately between IP principal companies. The company required a transfer pricing strategy that better reflected the economic contributions of its operations across key principal jurisdictions.
CRA’s Gene Tien designed a cost-sharing strategy to help the client operate more efficiently. Dr. Tien’s deep expertise in cost sharing for West Coast digital companies, knowledge of relevant tax jurisdictions, and extensive experience in pharmaceuticals, supported the design of an appropriate global approach for this client.
The strategy helped to streamline coordination between outside advisors and support discussions with tax authorities on both sides of planning discussions, local audits, and ultimately bilateral advance pricing arrangement negotiations.
