VRC has noticed an emerging phenomenon: U.S.-based multinationals are taking steps to move intellectual property back into the U.S.
A leading high-tech materials and derivative precision components company engaged VRC to determine appropriate arm’s length royalty rates for IP for Transfer Pricing.
The OECD is moving in a direction similar to the U.S. in tightening controls.
In 2013, new cost sharing regulations became effective amid controversy surrounding the application of methods used in high profile court cases.
Comparability is the key factor in determining the arm’s length range.
In practice, there are certain requirements to be aware of when dealing with transfer pricing situations in China and Vietnam.
Canada, like the U.S., imposes a thorough set of documentation requirements, and imposes penalties for failure to comply.
Multinational companies face several compliance and planning issues.