Transfer Pricing: Considerations for U.S. Multinationals

The recent North American Free Trade Agreement (NAFTA) negotiations have shone a spotlight on the extent of the integrated nature of the North American economy. In many sectors, of course, U.S. companies have had a long-standing and significant footprint with related entities in Canada - whether Canadian subsidiaries, branches or affiliated companies - where goods, services, licence rights and/or intellectual property are transferred cross-border between the related entities.