Transfer Pricing

DRTP Consulting’s transfer pricing services are relevant to any business with international activities. In the last 20 years, the great majority of countries have implemented new transfer pricing rules aligned with the OECD Transfer Pricing Guidelines.

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We provide a full range of transfer pricing services across the entire transfer pricing lifecycle.


For companies planning to enter into cross-border transactions, including an acquisition or sale of a business, it is important to set proper transfer pricing policies.  We assist clients with the design and implementation of sustainable arm’s length transfer pricing policies to support the economics of these transactions.


Transfer pricing documentation requirements have been implemented globally.  More recently, the OECD’s BEPS initiative has increased the level of documentation required in the form of Master file, local file and Country-by-country reporting.

  • The Master file constitutes a common file for all entities of a multinational group of companies which provides a high-level overview of its global business and policies.
  • The local file focuses on material transactions between the local country affiliates located in different countries. It provides additional detail on the operations and transactions relevant to the jurisdiction.
  • The Country-by-Country (“CbyC”) Report provides summary data by jurisdiction including revenue, income taxes, and indicators of economic activity. This report will be filed with the parent country tax authority who will automatically share it with countries in which the group operates.

DRTP Consulting performs all the steps necessary for the preparation of transfer pricing documentation. Types of intercompany transactions include:

  • Tangible good transactions
  • Intangible property transactions
  • Intragroup service transactions
  • Financial transactions such as intercompany loans, guarantees, cash pooling, etc.
  • Cost contribution arrangements

Controversy and Dispute Resolution

Tax authorities around the world are increasingly aggressive in protecting their tax base.  This has led to increased audit activity by fiscal authorities with respect to cross-border transactions within multinational companies.

We provide clients with proficient and cost-efficient transfer pricing dispute resolution services.  These services can be provided in the context of local tax and competent authority negotiations as well as advance pricing agreements.

Other International Tax Issues

International tax issues may arise from transfer pricing structures.  DRTP Consulting provides services associated with treaty-based requests, returns and waivers as well as international tax issues related to international intercompany transactions, including:

  • Permanent establishment
  • Double taxation of income from real property or business profits
  • Tax withheld on dividends, interests, royalties, management fees, services provided by non-residents, income from real property
  • Issues on income from interest or related to capital gains
  • Double taxation arising from employment income, pension and annuities
  • Part XIII Tax withholding under the Canadian Income Tax Act
  • Regulations 102 and 105 withholding waivers
  • Double taxation on other types of income
  • Foreign tax credit