CRA was engaged by a mid-market North American online retail consumer products company to perform a North American transfer pricing planning study. The study involved the implementation, benchmarking, and documentation of an online retail distribution transaction, as well as a management services transaction. Additionally, a team of CRA consultants assisted management with the creation of a management fee cost allocation model, so that the appropriate charge could be accurately determined and the pricing policies properly adhered to. CRA’s team prepared the North American planning study, including OECD Master File and Local File compliant documentation.
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...