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.
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...