CRA was engaged by a mid-market global SaaS/software technology company to provide global transfer pricing planning and intangible restructuring advisory assistance. CRA was intricately involved in implementing a strategy of centralizing the IP, which was previously owned on a very decentralized basis, including performing the corresponding IP transfer valuations. CRA also prepared the global planning study, including OECD Master File and Local File compliant documentation, with respect to all of the intercompany transactions, including: marketing intangibles, technology intangibles, loan interest, and various types of operational services. The benchmarking analyses addressed operations in various geographic areas, including: North America, Europe and Asia-Pacific.
Intangible Planning & Restructuring for Technology Company