CRA assisted US and non-US pharmaceutical companies on their outbound IP royalties in response to commensurate with income (CWI) considerations.
Recent changes to drug pricing regulations and positions taken by the IRS relating to CWI necessitated deeper analyses of their existing transfer prices. Gene Tien conducted multiple analyses, including reviews of comparable uncontrolled transactions and IRS-favored methods to support ongoing arm’s length pricing.
Attest firms and foreign tax authorities accepted the pricing as developed by CRA, which worked in conjunction with multiple US and European attest firms and legal advisors to achieve this objective.
