Transfer Pricing

The transfer pricing practice of Gottlieb & Associates focuses on customs valuation of sales transactions involving sales of goods and services and licensing of intellectual property between foreign and Canadian related parties. Working with other service providers, Gottlieb & Associates is also able to offer services dealing with income tax aspects of transfer pricing.

In advising clients on the structuring of transfer pricing for customs purposes, we closely analyze the dutiable and non-dutiable elements of these transactions and advise on the allocation of value to each element so as to minimize the amount of customs duties and goods and services taxes payable, while at the same time preserving the benefits of income tax planning. The analysis considers both whether or not specific payments are dutiable and the rate of duty applicable to specific goods by virtue of either their tariff classification or the applicability of tariff preferences.

We also work with clients to ensure that they are in a position to demonstrate that the relationship between parties to transactions involving transfer pricing has not influenced the price paid or payable, and in doing so, ensure the application of the transaction value where this is the preferred customs valuation methodology.

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