[Verse 1] When you own companies across the border line Canadian resident with US ties that bind Transfer pricing rules will find your structure soon Documentation needed or you'll sing a different tune Multiple entities under common control Arm's length pricing is the ultimate goal Related parties can't just set their rates at will IRS and CRA are watching every bill [Chorus] Price it right, document tight, arm's length all the way Management fees, royalties, what would strangers pay? Twenty percent penalty waiting if you're wrong Transfer pricing compliance keeps your business strong [Verse 2] Intercompany transactions need their paper trail Management services and licensing without fail Cost sharing agreements and the loans between Every dollar flowing needs its pricing clean Economic substance must support each deal you make Comparable transactions set the rates you'll take Third party evidence will build your defense case When auditors come knocking at your corporate space [Chorus] Price it right, document tight, arm's length all the way Management fees, royalties, what would strangers pay? Twenty percent penalty waiting if you're wrong Transfer pricing compliance keeps your business strong [Bridge] Canada hits you with twenty percent fine US can double that if they decline Your pricing study and contemporaneous files Could save you thousands and reduce your trials [Verse 3] Solo operator needs a simple plan Service company billing what the market can Reasonable markup on your costs incurred Management fees for every service transferred Keep it clean and simple, document every choice Let comparable data be your pricing voice Arm's length principle guides your every move Transfer pricing compliance helps your profits groove [Chorus] Price it right, document tight, arm's length all the way Management fees, royalties, what would strangers pay? Twenty percent penalty waiting if you're wrong Transfer pricing compliance keeps your business strong [Outro] Cross-border structures need their pricing right Documentation ready for the audit fight
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