- Transfer-pricing studies
- review and evaluate transfer-pricing practices;
- outline possible areas of exposure;
- prepare supporting evidence and contemporaneous documentation, including functional and economic analyses;
- determine reasonable arm's-length pricing policies where applicable; and
- prepare reports on the overall reasonableness of the arrangements and compliance with tax regulations.
- Mock audits and audit assistance
- identify areas of exposure,
- reduce the risk of potential adjustments and penalties,
- assist with transfer-pricing audits by tax authorities,
- prepare supporting analyses, and
- negotiate to reduce potential adjustments.
- Advance pricing agreements
- assist in negotiating agreements with tax authorities, and
- provide supporting reports.
- prepare valuation reports to support transfers of intellectual property (software, licences, patents, copyrights, and so on); and
- validate royalty arrangements.
- Tax planning
- suggest ways to minimize transfer-pricing audit exposure,
- reorganize intercompany business models, and
- advise on transfer-pricing issues from both Canadian and international tax perspectives.
- Defence strategies
- develop strategies for negotiating and defending transfer-pricing policies and arrangements with tax authorities, and
- represent clients before the Canadian tax authorities when necessary.