CRA was engaged by a mid-market global automotive products company to perform a North American transfer pricing planning study. The study involved the implementation, benchmarking, and documentation of various types of transactions, including: marketing intangibles royalty, technology intangibles royalty, distribution, procurement, and management services. The transactions were each benchmarked directly, as well as indirectly rationalized via a secondary corroborating manufacturing analysis as an extra measure of support. CRA consultants prepared the North American planning study, including OECD Master File and Local File compliant documentation. Additionally, we assisted management with the creation of operationally segmented financials, so that the appropriate profit level indicators could be accurately determined, and the pricing policies properly adhered to.
Who bore the tariff burden? Economics of IEEPA refund disputes
The refund question sits at the intersection of customs procedure, administrative law, but also economics, and resolution will likely vary significantly across...