Transfer Pricing for Technology & Software Services

Global Transfer Pricing Strategies for the Sector Technology & Software Sector

Empowering global technology leaders to manage intellectual property, licensing, and R&D cost structures through compliant and strategic Transfer Pricing solution

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Ensure global compliance with Transfer Pricing in the Technology & Software industry.

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Leading transfer pricing firm
WHY CHOOSE US

Why Choose Us for Technology & Software Transfer Pricing?

The technology sector evolves rapidly — with digital assets, cloud computing, and cross-border licensing becoming core value drivers. Our Transfer Pricing services are designed to ensure compliance while enhancing profitability and IP protection.

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01

Transfer Pricing strategy

for software licensing and digital delivery models.
02

Benchmarking analysis

for royalties, cost contributions, and contract R&D.
03

Comprehensive documentation

compliant with OECD Transfer Pricing Guidelines.
04

Risk mitigation for digital IP

migration, valuation, and audits.
Technology & Software
Industries We Support

Customized Transfer Pricing Support for Technology Innovators

  • Software & SaaS Providers:Arm’s length pricing for IP, licenses, and maintenance fees.
  • Cloud Infrastructure & IT Services: Benchmarking and cost contribution arrangements.
  • E-Commerce & Digital Platforms: Cross-border transaction mapping and profit allocation.
  • AI, Data & Gaming Companies:Valuation of proprietary algorithms, data rights, and content IP.
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Technology & Software Industry

Major Transfer Pricing Issues in the Technology & Software Industry

Technology companies operate globally with complex intangible ownership, digital transactions, and evolving regulatory expectations. Authorities like the OECD and CRA emphasize the arm’s length principle for IP-heavy businesses. Ensuring defensible pricing models and transparent cost allocation is critical for minimizing Transfer Pricing risk.

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Software, patents, and proprietary algorithms are the backbone of tech firms.
Determining arm’s length values for these intangibles ensures compliance and fair profit allocation.
Tech companies often share development costs across jurisdictions.
Structured cost-sharing models help document contributions and maintain OECD-aligned Transfer Pricing studies.
Intercompany licensing for software, digital tools, and technology platforms requires robust benchmarking to justify royalty rates and support Transfer Pricing documentation.
Allocating revenue for SaaS, hosting, and support services among group entities ensures transparent profit distribution and defensibility in audits.
omparables for cutting-edge technology models are scarce.
We use functional analysis and statistical adjustments to strengthen Transfer Pricing reports.
Tech companies must maintain global documentation consistent with OECD Transfer Pricing Guidelines while addressing unique IP, data, and digital asset considerations.
Tax authorities focus heavily on IP transfers, valuation shifts, and profit attribution. Our strategies minimize exposure and provide clear defensibility during audits.
our pricing

Clear, Competitive Packages Tailored for Your Transfer Pricing Needs

Basic Transfer Pricing Benchmarking

$2,500 (one-time)
Coverage:
Benchmarking analysis for a single intercompany transaction.
Deliverables:
Industry-specific benchmarking study
Arm’s length pricing support
OECD-compliant benchmarking documentation
Perfect for businesses that only need standalone benchmarking without full documentation.
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Standard Transfer Pricing Study

$3,500 (one-time)
Coverage:
Comprehensive transfer pricing study for one transaction type.
Deliverables:
Functional and economic analysis
Selection of the most appropriate transfer pricing method
Benchmarking analysis
Documentation (Master File & Local File) in line with OECD and CRA guidelines
Designed for businesses requiring a complete transfer pricing report for CRA compliance.
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Premium Transfer Pricing Study

$4,500 (one-time)
Coverage:
Financial transaction benchmarking or two types of transactions.
Deliverables:
Benchmarking for intercompany financial transactions (e.g., loans, guarantees)
Full documentation package (Master File & Local File)
Strategic pricing insights and documentation for high-risk or high-value transactions
Ideal for businesses with complex structures or cross-border financial arrangements.
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Our Team Experts

Experienced Transfer Pricing Advisors at Your Service

Udit Gupta

Partner
transfer pricing documentation

Abhinav Gupta

Partner
Abhinav Gupta

Raghav Gupta

Partner
Raghav Gupta

Deepanshu Bansal

Transfer Pricing Expert
Deepanshu Bansal

Shreya Jain

Transfer Pricing Consultant
faq

Transfer Pricing for Technology & Software Industry

Get clarity on the most common questions our clients ask about Transfer Pricing in the technology and software sector.

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Why do technology and software companies need Transfer Pricing documentation?

Technology and software companies operate across multiple jurisdictions through licensing, R&D, and digital service models. Proper Transfer Pricing documentation ensures compliance with OECD Transfer Pricing Guidelines, minimizing risks from tax adjustments, audits, and double taxation.

What types of Transfer Pricing documentation do you prepare?

We prepare comprehensive, audit-ready Transfer Pricing studies including:

  • Master File and Local File reports for technology entities.
  • Benchmarking for software development and licensing fees.
  • IP valuation and royalty rate analysis.
  • Cost-sharing and R&D expense allocation documentation.
How do you determine arm’s length pricing for software and IP transfers?

We apply royalty benchmarking and profit split methods, analyzing comparable licensing models from global tech firms. This ensures pricing for patents, software, and algorithms is both defensible and OECD-compliant.

Do you assist with Transfer Pricing audits or CRA reviews?

Yes. We provide full Transfer Pricing audit defense and dispute support, helping you substantiate your software development costs, IP ownership structures, and intercompany royalty arrangements.

Are your consultants experienced in the technology and software industry?

Our consultants have deep expertise in software, SaaS, fintech, and digital services, with extensive experience advising global IT companies on intercompany pricing and IP valuation.

What regions do you serve?

We serve technology clients across Canada, the U.S., Europe, and Asia-Pacific, ensuring globally consistent Transfer Pricing documentation and compliance frameworks.