CRA is assisting a large computer manufacturing taxpayer in assessing the arm’s length nature of payments to manufacturing subsidiaries. Work involves reviewing the characterization of the functions performed by the different entities and evaluating how the corresponding risks and returns are allocated between those entities.
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...