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
    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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  • 02
    Intangible Planning & Restructuring for Technology Company
    CRA was engaged by a mid-market global SaaS/software technology company to provide global transfer pricing planning and intangible restructuring advisory...
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  • 03
    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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