Oil & Gas: Transfer pricing

Companies that have, or are planning, domestic or international operations inevitably face the necessity of satisfying worldwide transfer pricing requirements. Setting arm’s-length prices for products, intangibles, services, or financial transactions is a delicate and demanding task, but one that CRA has an exceptional capacity to meet. We have 20 years of experience with transfer pricing issues and have been involved in transfer-pricing case work in more than 20 countries.

With experience advising businesses, their legal counsel, and governments worldwide, CRA can assist in every phase of the tax cycle, including planning, documentation, FIN 48, and tax valuation. We also provide audit defense and support in litigation and alternative dispute resolution.

Our specialists can help develop and analyze transfer pricing structures and comparable transactions, determine appropriate prices, and produce the documentation that is required to avoid transfer pricing penalties that can be imposed by many tax jurisdictions. We offer any one or a combination of these services:

• Transfer pricing planning
• Audit/APA/competent authority support
• Documentation for compliance purposes
• Litigation support 
• FIN 48