CRA assisted a software company with the integration of acquired technology into an existing qualified cost sharing arrangement with consideration of the appropriateness of carve-outs. Additional work included the alignment of functional returns for acquired subsidiaries with the transfer pricing policies of the acquirer.
Highlights from 2025 and looking forward to 2026
In the United States, 2025 brought major activity in high profile transfer pricing disputes and reaffirmed how closely transfer pricing, tariffs, and customs...