CRA was engaged by a leading global health products company to perform a global transfer pricing planning study. The study involved the benchmarking and documentation of over 10 different types of transactions, including: marketing intangibles, technology intangibles, procurement services, contract R&D services, contract manufacturing services, distribution of raw materials, distribution of finished goods, and various types of operational services. The benchmarking analyses addressed operations in various geographic areas, including: North America, Europe and Asia-Pacific.
Who bore the tariff burden? Economics of IEEPA refund disputes
The refund question sits at the intersection of customs procedure, administrative law, but also economics, and resolution will likely vary significantly across...