Transfer pricing

In the process of globalization, the area of multinational or local intercompany transactions is getting bigger awareness of tax authorities. That is the reason why companies need to take in consideration appropriate setting of transfer pricing policy.

Our experts can identify and address any tax pitfalls or issues. Our aim is to help our clients to implement tax-efficient transfer pricing policies and in order to control the underlying dynamic circumstances.

There is a wide range of services provided within our transfer pricing team, which in general can be divided into two categories: TP compliance services and TP advisory services.

TP Compliance services

Transfer pricing documentation

Preparation of TP documentation based on the character of transaction under review in compliance with local and international tax legislation.
Comparable analysis ("Benchmark")

Preparation of appropriate comparable analysis by using of state-of-the-art databases, in order to prove the arm´s length nature of the respective transactions. We always pay attention to the practical capability of the results in respect of tax administration.

TP Advisory services

Efficiency analysis

Preparation of analysis that serves as a defence file in a case of tax audit and clarifies reasonable causes of profit fall, business efficiency or other significant changes in different fields of business.
Tax advisory

Provision of comments on particular business cases including proposed solutions.
Litigation

Assistance and representing the interests of a client in a case of tax audit, communication with tax authorities, preparation of tax advisor´s opinion for tax authorities, preparation of all necessary documentation.
Advance Pricing Agreement (APA)

Preparation of an ahead-of-time procedural agreement between taxpayer and tax authority on determining an appropriate transfer pricing methodology for a set of controlled transactions over a fixed period of time to secure the arm's length principle compliance.
Mutual Agreement Procedure (MAP)

Preparation of such instrument allows designated representatives from the governments of the contracting states to interact with the intent to resolve international tax disputes regarding the application of double taxation conventions.
Transfer pricing mechanism and policy setting

Preparation of mechanism proper and suitable for a client based on all specific features and characteristics of the particular business in compliance with legislative requirements in transfer pricing area to achieve optimal results from an economic and tax perspective.
European Union Allowance (EUA)