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.
Highlights from 2025 and looking forward to 2026
In the United States, 2025 brought major activity in high profile transfer pricing disputes and reaffirmed how closely transfer pricing, tariffs, and customs...