"Transfer Pricing"

Transfer Pricing

Whether you seek to develop and analyze transfer pricing structures, identify and evaluate comparable transactions, prepare tax valuations or develop strategies for the successful resolution of transfer pricing controversies, we can help. Our team, consists of renowned transfer pricing experts who deliver understandable analysis, clear testimony and practical recommendations for specific actions. We offer unmatched functional, industry and international expertise as well as the most rigorous economic and financial analysis available.

Transfer Pricing Services

Documentation and BEPS Compliance

CRA has prepared transfer pricing documentation for use across the globe. Our documentation helps multinational companies mitigate their audit risk and defend their transfer pricing policies when audits occur. CRA prepares transfer pricing documentation that satisfies Internal Revenue Code (IRC) Section 6662(e) and meets the requirements of revenue agencies across the globe. We prepare documentation studies and pricing analyses for all types of transactions, including tangible and intangible goods transactions, intercompany service transactions, cost-sharing arrangements, and financial transactions.

CRA has developed a proprietary diagnostic platform that assists multinational companies’ self-check on their Country-by-Country Reporting. CRA maintains a live cheat sheet of BEPS Action 13 (i.e., Country-by-Country Reporting, Master File, Local File) implementation status by jurisdiction, as well as traditional transfer pricing documentation requirement, which is applicable for jurisdictions that have not implemented BEPS Action 13.


CRA helps companies reduce risk and develop creative yet sound transfer pricing planning strategies and practical transfer pricing policies that respect the arm’s length standard.

CRA provides transfer pricing advice in relation to all types of planning arrangements, including planning for and negotiating advance pricing agreements (APAs), pricing all types of intangible assets transferred during a business restructuring and analyzing the allocation of risks (and associated transfer prices) between related companies. Clients in many sectors and industries, including consumer products, energy, pharmaceutical, and technology, have relied on our planning advice. We have also been called upon to provide objective assessments of strategies developed by other firms.

Advance pricing agreements (APAs)

CRA provides clients with the transfer pricing and economic expertise needed to negotiate favorable APAs. We assist in all stages of the process, from determining whether an APA would benefit a company’s tax position to recommending a transfer pricing methodology. We also prepare initial APA requests and support economic analyses to negotiate with tax authorities on a company’s behalf as well as prepare annual documentation of compliance with the APA and assist with renewal strategy.

Our transfer pricing professionals have structured and negotiated numerous unilateral and bilateral APAs. These have included inbound and outbound transactions of tangible and intangible products across a number of industries and countries, including Australia, Canada, France, Germany, Japan, the Netherlands, the United Kingdom, the United States, and other countries.

Tax valuation

CRA has extensive experience advising multinational clients on the value of their intellectual property, technology, trade names, and other intangible assets during transfer pricing proceedings. Our experts have provided expert witness testimony before the US Tax Court, and they possess the experience and judgment needed to tailor economic and financial models based on the unique facts and circumstances of each case.


From planning a new transfer pricing arrangement to testifying as experts in US or foreign courts, CRA provides comprehensive audit and litigation support services during transfer pricing controversy. We have supported clients under audit by tax authorities or engaged in competent-authority proceedings in Australia, Canada, Italy, France, Germany, Hong Kong, Japan, Malaysia, the Netherlands, Norway, Singapore, Switzerland, the United Kingdom, the United States, and other countries.

FIN 48

CRA has prepared FIN 48 analyses for a number of multinational companies. Our analyses draw on our vast experience in audit and controversy work involving tax authorities across the globe and our ability to apply sound economic analysis to value the tax result associated with alternative tax positions in a manner that is likely to prevail in controversy, either at the local or competent authority level.

Regulation and Policy Advisory

As a member of the Business and Industry Advisory Committee to the OECD, CRA is directly involved in the significant revisions to transfer pricing guidelines that the OECD plans to finalize in 2015, as mandated by the G20-OECD action plan on BEPS (Base Erosion and Profit Shifting).

Industry expertise

Our transfer pricing team is supported by a broad spectrum of resources, enabling us to leverage key skills and deep industry knowledge to the benefit of our clients. Together, our consultants offer world-class expertise in multiple disciplines and industries, including, but not limited to, airline, automobile, computer hardware and software, consumer products, durable products, energy, financial services, health care, heavy manufacturing, pharmaceuticals, retail, real estate, telecommunications, and various utilities.