CRA resolved an issue at Appeals relating to management fees for a Silicon Valley client. At issue was the beneficial allocation of expenses and the measurement of stock-based compensation. Rebel Curd successfully argued that the client’s beneficial allocation percentage was the most objective measure and that the client maintained sufficient books and records for the use of the fair value method for the inclusion of stock-based compensation. The case was resolved with zero adjustment.
CRA acknowledged in ITR's 2023 World Transfer Pricing Guide
CRA is pleased to be acknowledged in International Tax Review’s (ITR) 2023 World Transfer Pricing Guide as one of the “leading” transfer pricing practices in...