Several jurisdictions, including Germany and Colombia, have withholding tax requirements for transfers of IP registered in their countries, irrespective whether the transferor or transferee is located in that jurisdiction. Analysis of the withholding tax liability is an important part of planning for intra-group IP transfers, as well as a compliance requirement upon execution of the transaction. CRA’s experts in transfer pricing have been engaged on numerous occasions to assess withholding tax liabilities specific to the IP registered in various countries in conjunction with large scale IP transfers.
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...