CRA assisted a software company with the integration of acquired technology into an existing qualified cost sharing arrangement with consideration of the appropriateness of carve-outs. Additional work included the alignment of functional returns for acquired subsidiaries with the transfer pricing policies of the acquirer.
Highlights from 2024 and looking forward to 2025
In this Insights, our transfer pricing consultants reflect on significant transfer pricing developments in 2024 and anticipate trends for 2025. We begin with...