Highlights from 2023 and looking forward to 2024
In this Insights, our transfer pricing consultants summarize key transfer pricing developments in 2023 and look ahead to 2024 where we expect the economic...
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
- 01Assisting European multinationals with TP planning for US organic growth and M&ACRA’s Gene Tien assisted multiple foreign-parented companies in navigating the complexities of expanded US operations. For the past decade, the relatively...View engagement
- 02EMEA ruling and audit defense assistance for IP restructuringCRA’s Gene Tien assisted on multiple IP planning matters involving IP transactions related to life sciences, the digital economy, and financial services in...View engagement
- 03Automation of intercompany pricing in ERP systemsThis requires the translation of aggregate intercompany pricing policies into a set of transaction-level pricing rules, which can be a complex exercise for...View engagement
Meet our team
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Rebel CurdVice President, Practice Leader of Transfer Pricing
Oakland
+1-510-595-3098 rcurd@crai.com![]()
David KempVice President, Transfer Pricing Leader for Canada
Toronto
+1-416-323-5563 dkemp@crai.com![]()
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