Transfer Pricing

Our firm has many years of experience working with companies to minimize transfer pricing risk.

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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.

Our firm helps companies and their advisors:

  • Set and review transfer prices using our transfer pricing economics expertise and many years of in-depth commercial experience;
  • Meet transfer pricing documentation compliance requirements worldwide in a practical and efficient manner;
  • Support international tax plans with transaction and pricing analysis;
  • Navigate through transfer pricing audits, disputes, appeals, and Competent Authority matters ; and
  • Learn how to take more transfer pricing duties in-house by transferring knowledge.

Cadesky Tax has extensive experience delivering services in a globally coordinated and locally informed way. In addition to our Canadian and U.S. transfer pricing resources, we also work cooperatively with colleagues around the world to deliver transfer pricing services to multinational companies.

Our Services include:

Transaction planning and business structure optimization
  • Recommend transaction structures and related-party pricing methods as part of an international tax plan to meet business objectives;
  • Analyze feasibility of international business restructuring transactions and reorganizations;
  • Determine prices for transactions with permanent establishments (branches);
  • Review transaction structures and pricing policies against transfer pricing rules and tax efficiency objectives;
  • Provide a balanced view of Canadian and international technical requirements;
  • Determine debt capacity and arm’s length debt structure for intercompany loans and guarantees;
  • Assist with the implementation of transfer pricing policies and intercompany transactions;
  • Coordinate customs and value for duty methods with income tax;
  • Advise on management of transfer pricing audit and tax provision risk.
Transfer pricing audit dispute resolution
  • Assist with technical arguments, economic analyses and strategy during the audit stage;
  • Meet with tax authority auditors and economists to assist in navigating the tax authority organization structure and obtain the best outcome;
  • Support legal counsel and tax advisors in transfer pricing dealings with the tax authority;
  • Negotiate to reduce potential adjustments;
  • Assist with Appeals filings and procedures, Competent Authority submissions and procedures, and voluntary disclosures;
  • Provide litigation support on Tax Court of Canada matters.
Contemporaneous documentation
  • Prepare industry analysis, functional analysis and financial/economic analysis to meet Canadian and international documentation requirements;
  • Assist with coordinated global documentation compliance;
  • Adapt foreign documentation to meet the Canadian reasonable efforts standard.
Advance Pricing Arrangements (APA)
  • Assist in assessing feasibility of an APA against alternatives, prepare pre-filing materials;
  • Preparation of APA request materials, including transfer pricing studies;
  • Support tax authority negotiation process, economic analysis
  • APA renewals and renewal review support.