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.
Transfer Pricing: 2022 in review
Our work during 2022 spanned from assisting start-up companies expanding abroad for the first time to advising large multinationals on multibillion-dollar...