CRA assisted a US-based technology company with an economic analysis that underpinned its advanced pricing agreement negotiation at its international HQ.
The uptick in global tax disputes necessitated a rethinking of the company’s transfer pricing strategy to manage HQ double taxation. CRA performed a pre-emptive assessment of the company’s evolving technology from a transfer pricing defense perspective, balanced evolving global transfer pricing policies reflected in the benchmarking analyses, and addressed tax authority questions to assist in pricing negotiations.
Gene Tien and Haruka Abe performed numerous analyses for their advanced pricing submissions, which were deployed efficiently for local country documentation. The team worked in conjunction with European tax legal advisors to achieve positive outcomes.
