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January 18, 2019

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Transfer Pricing Overview

Transfer pricing is one of the most challenging areas of international tax today. Multinational companies that conduct related-party transactions across borders use transfer prices to determine the value of products, services, intangible assets (i.e. rights, trademarks and designs), cost sharing/cost contribution payments, and financial instruments. Tax authorities worldwide are conducting increasingly skilful audits of corporate taxpayers to ensure compliance with the arm\'s length principle, and to control presumed base erosion and profit shifting practices. Transfer pricing legislation and guidelines differ between countries, and are presently in a state of change at the country level and at multilateral institutions like the Organization for Economic Cooperation and Development (OECD), the United Nations, and the European Union. Companies need practical assistance to:

  • understand how the law and often unpublished administrative practices of tax authorities is connected to tax and business risk,
  • make a good-faith effort to determine and use arm\'s length transfer prices that fit the business model,
  • select and apply a transfer pricing method and transfer price that maximizes value for shareholders,
  • maximize the likelihood of a good outcome in the event of an international tax audit.

Cadesky and Associates has extensive experience delivering this assistance in a globally coordinated and locally informed way through our affiliation with the Ruchelman Law Firm (U.S. transfer pricing, Competent Authority and Advance Pricing Arrangement matters) and worldwide through our Transfer Pricing Associates network.

Cadesky and Associates LLP is a Canadian member of TPA Global, a global network of independent experts that provide international businesses with integrated solutions to improve financial performance, maximize operational efficiency and support strategic and human capital development. To learn more about TPA Global, please visit www.tpa-global.com