CRA was engaged by a mid-market global SaaS/software 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, technical services, and management services. The transactions were each benchmarked directly, as well as indirectly rationalized via a secondary corroborating distribution analysis as an extra measure of support. We prepared the North American planning study, including OECD Master File and Local File compliant documentation.
Highlights from 2023 and looking forward to 2024
In this Insights, our transfer pricing consultants summarize key transfer pricing developments in 2023 and look ahead to 2024 where we expect the economic...