Transfer Pricing experts in our network provide a full range of services from provision of APAs to handling large global assignments including Country by Country Reporting. We assist in corporate decision-making at all stages of inter-company transactions by providing tailored solutions i.e. planning, policymaking, implementation, documentation and compliance along with assisting clients in contacts with tax authorities.
Transfer Pricing Design
We have extensive experience in designing and implementing transfer pricing policies that support new and existing business models and satisfy the arm's length principle. Gaining a sound understanding of clients’ business model is the key and the starting point for our services. We do not rely on one-size-fits-all type of solutions, but rather strive to support clients in performing targeted improvements to existing system.
Verification of the obligation to prepare transfer pricing documentation based on the provided financial data
We elaborate transfer pricing documentation files (Local Files, Master File) and benchmarking studies with the prime objective to manage transfer pricing risk and document a uniform transfer pricing methodology of transactions between related entities. Process means reviewing of legal ownership and geographical location of operations and determination of drivers of profit.
Transfer Pricing Reviews
As tax authorities increase their control over transactions with related parties, organisations must be proactive in managing their transfer pricing risks. Our experts have experience in carrying out the following types of transfer pricing reviews: review of transactions in terms of TP regulations, reviews of transfer pricing documentation, reviews of existing intercompany relations (mapping), reviews of supporting documentation for TP purposes. Applying a correct transfer pricing policy may not only allow a multinational group to reduce potential tax risks, but it may also create tax opportunities.
Drafting of Transfer Pricing Documentation
We have substantial experience in providing advice through developing Advanced Pricing Agreement (APA) methodologies and in assisting clients in negotiating them with relevant tax authorities. First step is to analyse group TP policies and documentation and drafting an APA to include outline of business model and economic studies. We always suggest performing annual review of clients’ performance in relation to the APA.
Overall Transfer Pricing Services
From the preparation of intra-group agreements to benchmarks and documentation necessary to conduct the audit and tax proceedings - every topic related to your group settlements is a priority for us. Our goal is to identify and secure potential risk areas while taking into account your business and financial objectives.
Based on our experience in economic analysis and financial modelling, we provide services of valuation of companies and fixed assets, including intangible assets.