CRA was engaged by a leading global medical device company to provide global transfer pricing advisory. CRA has been instrumental in all parts of its transfer pricing analyses, including IP onshoring, planning, global documentation compliance, audit support, quarterly/year-end support as needed.
OECD issues guidance on transfer pricing implications of COVID-19
The Guidance is not prescriptive and leaves solutions to the issues that it raises unanswered. We note that the Guidance is not binding on tax administrations...