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Transfer Pricing

Transfer Pricing

We have extensive experience advising emerging businesses and multinational organizations through all aspects of their tax management lifecycle – planning, implementation, compliance, and controversy. We help you ensure that your tax positions are practically and properly aligned with your business operations.

We can help your company with all aspects of transfer pricing, including:

  • Planning and Implementation – Design new tax structure as you grow globally and move business functions to new locations.
  • Documentation – Prepare Canadian and OECD-compliant contemporaneous documentation reports for the jurisdictions in which your business operates.
  • Audit Support and Defense – Defend your transfer pricing policy with CRA or foreign tax authorities. Likewise, we can help limit uncertainty with your transfer pricing policy by pre-negotiating your position with tax authorities through private rulings or, the Advanced Pricing and Mutual Agreement Program.
  • IP/Cost Sharing Planning – Properly value IP for tax purposes in order to safeguard against tax authorities claiming that IP rights were transferred without reasonable compensation.
  • Country by Country Reporting (CbCR) – As BEPS Action 13 continues to be implemented by an increasing number of countries, it is imperative for businesses (especially large enterprises) to ensure that the narrative of the CbCR forms accurately reflects where their functions, assets and risks are located, and does not suggest one that allows tax authorities to impute an alternative interpretation more to their liking.

Our approach to transfer pricing is built to provide solutions that are clear, comprehensive, concrete and convincing. Contact our experienced Andersen professionals help you solidify your transfer pricing position.

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