CRA was engaged by a mid-market North American online retail consumer products company to perform a North American transfer pricing planning study. The study involved the implementation, benchmarking, and documentation of an online retail distribution transaction, as well as a management services transaction. Additionally, a team of CRA consultants assisted management with the creation of a management fee cost allocation model, so that the appropriate charge could be accurately determined and the pricing policies properly adhered to. CRA’s team prepared the North American planning study, including OECD Master File and Local File compliant documentation.
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...