CRA Insights

Highlights from 2024 and looking forward to 2025

December 17, 2024
Global-network-cyber-international

In this Insights, our transfer pricing consultants reflect on significant transfer pricing developments in 2024 and anticipate trends for 2025.

We begin with discussions of the key challenges and considerations in the coming year, including the implementation of Amount B and strategies for companies managing intercompany transactions in an increasingly complex tax landscape, especially under the heightened focus on trade policies following the US presidential election. A dedicated section compares the UN and OECD transfer pricing guidance, highlighting key differences in approach and their practical implications for multinational enterprises operating in emerging markets.

We highlight the themes of some of our projects undertaken in 2024, including global benchmarking, intangible property valuation, compliance documentation, dispute resolution, and litigation support. Additionally, we provide updates on noteworthy transfer pricing court cases, global regulatory changes, and insights into how evolving economic conditions continue to influence transfer pricing dynamics.

Click here to read more about our 2024 review and what is upcoming in 2025

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