technology
Services

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

Engagements

  • 01
    Advised on transfer pricing and customs for importer into China
    US hardware manufacturer imported finished goods into China at a transfer pricing that left China with a small profit. When the Chinese customs authority...
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  • 02
    Withholding tax analysis for IP transfers
    Several jurisdictions, including Germany and Colombia, have withholding tax requirements for transfers of IP registered in their countries, irrespective...
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  • 03
    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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