CRA has advised a major software company on a series of IP transactions in response to US tax reform and BEPS, including terminating a qualified cost sharing arrangement as well as valuations for ORIP purposes in the UK, onshoring IP into Ireland and withholding on IP licensing in Germany pursuant to Section 49.
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...