Transfer pricing today is one of the key aspects of a company’s tax planning and economic risk management. Transfer pricing rules are important to consider when conducting operations with foreign counterparties.
Taking into account the constant changes in Transfer pricing legislation, the presence of significant fines and control by tax authorities, we advise our clients to pay special attention to the definition of the list of controlled transactions, their proper justification in the Transfer pricing Documentation and the timely submission of the Report on controlled transactions (CO) and Notification of participation in multinational enterprise (MNE).
We offer:
| TP Consulting: | |
| - | application of legislation; |
| - | determination of the list of operations for testing compliance with the “arm’s length” principle; |
| - | business purpose test; |
| - | checking the completeness and correctness of existing TP documentation; |
| - | preparation of the TP annex to the income tax declaration. |
| TP Reporting: | |
| - | advising on the preparation of a Report on CO, Notification of participation in the MNE; |
| - | preparation and verification of the Report on CO; |
| - | preparation of a Notification of participation in the MNE. |
| TP Documentation: | |
| - | preparation/updating of Documentation or its part; |
| - | description of the CO, analysis of functions and risks; |
| - | justification of the choice of method; |
| - | economic and comparative analysis; |
| - | definition of the market range; |
| - | development of TP policies. |
| Support during inspections: | |
| - | assistance in preparing for TP inspections; |
| - | preparation of answers to requests from tax authorities; |
| - | maintenance of disputes with regulatory authorities; |
| - | appealing decisions of tax authorities. |
