Transfer pricing memorandum and study, value chain design, functional analysis and economic analysis, comparables search.
International tax audit and tax dispute management, objection and appeal, case law research, voluntary disclosure.
Design and documentation, audit and dispute management, double tax matters, and APA.
Transfer pricing memorandum and study, BEPS risk analysis, transfer pricing method, profit margin, mark-up on cost, benchmarking study.
The blog on transfer pricing in Canada, the USA and the OECD.