A North American telephone call centre operator sought our assistance to respond to transfer pricing document requests from Canada Revenue Agency. The total value of the transfer pricing transactions during the relevant period was over $150 million.
We assisted our client to assemble the required documentation and present information to Canada Revenue Agency that complied with the requirements set out in the Income Tax Act for preparation of contemporaneous documentation.
In order to support our client’s transfer pricing methodology, we considered and utilized several different transfer pricing approaches. We also attended meetings with representatives of Canada Revenue Agency and the Internal Revenue Service to discuss settlement options. This matter is now proceeding to Competent Authority, being the process pursuant to which Canada Revenue Agency and the Internal Revenue Service determine the allocation of taxes.