CRA was engaged by a mid-market global technology company to perform a global transfer pricing planning study. The study involved the implementation, benchmarking, and documentation of various types of transactions, including: marketing intangibles royalty, technology intangibles royalty, data center services, contract research and development services, and management services. The transactions were each benchmarked directly, as well as indirectly rationalized via secondary corroborating routine technology services analyses as an extra measure of support. The benchmarking analyses addressed operations in various geographic areas, including: North America and Europe. CRA’s team of consultants prepared the global planning study, including OECD Master File and Local File compliant documentation.
Significant tax risk to non-US companies created by America First Trade Policy
On his first day in office, President Trump signed two memoranda, the Global Tax Deal and the America First Trade Policy, covering noteworthy international...