CRA was engaged by a mid-market global technology company to perform a global transfer pricing planning study. The study involved the implementation, benchmarking, and documentation of various types of transactions, including: marketing intangibles royalty, technology intangibles royalty, data center services, contract research and development services, and management services. The transactions were each benchmarked directly, as well as indirectly rationalized via secondary corroborating routine technology services analyses as an extra measure of support. The benchmarking analyses addressed operations in various geographic areas, including: North America and Europe. CRA’s team of consultants prepared the global planning study, including OECD Master File and Local File compliant documentation.
Measuring and mitigating harm from discriminatory taxes
In the article the authors examine the April 2 Executive Order signed by President Trump highlighting US trading partners’ nontariff barriers, such as...