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 has 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.
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...