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.

Engagements

  • 01
    Automation of intercompany pricing in ERP systems
    This requires the translation of aggregate intercompany pricing policies into a set of transaction-level pricing rules, which can be a complex exercise for...
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  • 02
    Economic analysis of international hub and advanced pricing agreement negotiation
    The uptick in global tax disputes necessitated a rethinking of the company’s transfer pricing strategy to manage HQ double taxation. CRA performed a...
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  • 03
    Global transfer pricing design supports technology startup growth
    Our team worked with numerous local law firms to design and price commercially-rational and tax-efficient intercompany transactions to facilitate their startup...
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Meet our team

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