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.
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...