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.

Meet our team


  • 01
    Transfer pricing analysis during bankruptcy proceedings
    CRA was retained by counsel of European subsidiaries of Nortel in simultaneous bankruptcy proceedings in the U.S. and Canada. Our work involved determining $2...
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  • 02
    Technology Planning
    CRA has advised a major software company on a series of IP transactions in response to US tax reform and BEPS, including terminating a qualified cost sharing...
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  • 03
    Technology Transfer Pricing
    CRA is assisting a large computer manufacturing taxpayer in assessing the arm’s length nature of payments to manufacturing subsidiaries. Work involves...
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