The client (CanCo) is a Toronto-based, Canadian-owned manufacturer of parts for certain industrial systems. With $25 million in revenue, the company planned its first international push by establishing a US distributor, followed by distribution into Europe via third-party partners.
To comply with the OECD’s guidance, tax leaders at MNEs should have an understanding of all intercompany financial transactions and how changing conditions might affect the lender and borrower behaviours at arm’s length.
Expanding your business into new jurisdictions can unlock many benefits and opportunities; however, there are key factors to consider before taking the leap.
Transfer pricing is more than a compliance exercise—it’s an essential part of operating a multinational enterprise regardless of size.
A summary of most popular technology solutions that can assist with various elements of operational transfer pricing in order to meet compliance requirements.
Tech companies need focus on: their intellectual property (IP), remote workforce and funding arrangements for an effective transfer pricing framework
Rare decision by Tax Court of Canada ruling in favor of AgraCity Canada over transfer pricing dispute with CRA.
Transfer pricing dates back to 1917. Doane Grant Thornton LLP has developed a service model that is both a roadmap and a checklist relating to best practice transfer pricing governance processes and procedures.
