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.
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...