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.
Measuring and mitigating harm from discriminatory taxes
In the article the authors examine the April 2 Executive Order signed by President Trump highlighting US trading partners’ nontariff barriers, such as...