Several jurisdictions, including Germany and Colombia, have withholding tax requirements for transfers of IP registered in their countries, irrespective whether the transferor or transferee is located in that jurisdiction. Analysis of the withholding tax liability is an important part of planning for intra-group IP transfers, as well as a compliance requirement upon execution of the transaction. CRA’s experts in transfer pricing have been engaged on numerous occasions to assess withholding tax liabilities specific to the IP registered in various countries in conjunction with large scale IP transfers.
Drug pricing rules and tariffs reshape transfer pricing for IP
In the article “Drug Pricing Rules and Tariffs Reshape Transfer Pricing for IP,” published in Bloomberg Tax, CRA’s Transfer Pricing experts Robin Hart and ...