Technology Transfer Pricing

CRA assists many clients in the technology sector, including software, SaaS, IoT, digital marketplaces, fintech, hardware, and semiconductor companies navigate complex transfer pricing issues relating to IP valuation and digital services.  Our clients include venture-backed high growth companies that are expanding internationally via R&D locations or establishing a sales and marketing presence in major markets, as well as large profitable companies that are the subject of digital services taxes.  We have assisted clients in the technology industry to enter into cost-sharing arrangements and subsequently transfer IP in response to BEPS considerations.  CRA economists are frequently engaged to assist with dispute resolution relating to IP valuations for technology companies.


  • 01
    Global planning documentation for technology company
    CRA was engaged by a mid-market global technology company to perform a global transfer pricing planning study. The study involved the implementation,...
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  • 02
    North American planning documentation for SaaS/software company
    CRA was engaged by a mid-market global SaaS/software company to perform a North American transfer pricing planning study. The study involved the...
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  • 03
    Patent valuation for withholding tax purposes
    CRA was engaged by a Silicon Valley software company to prepare an economic analysis of the licensing of German registered patents for German withholding tax...
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