Transfer pricing services

Diagnostics of pricing in related party transactions

Our services include the evaluation of potential risks associated with your company’s existing transfer pricing policies by assessing the likelihood of challenges from tax authorities and the potential impact on your company’s tax liabilities.

In order to mitigate the transfer pricing risks we may review your inter-company business model and related party pricing arrangements, identify all the related party transactions subject to transfer pricing documentation, analyze the existing mechanism of setting transfer prices for controlled transactions to assess whether the terms of the intercompany transactions are consistent with the arm’s length principle.

Transfer Pricing compliance

Our services include the evaluation of potential risks associated with your company’s existing transfer pricing policies by assessing the likelihood of challenges from tax authorities and the potential impact on your company’s tax liabilities.

Our aim is to ensure that comprehensive, accurate, and tailored to the specific circumstances of your company transfer pricing documentation is in place.

TP defense strategy

Transfer pricing audit defence requires careful preparation, proactive engagement with tax authorities, and effective advocacy to justify the company’s transfer pricing practices.

We provide support to companies during the TP audit process by reviewing documents received by the tax authorities and preparing commments on the metholodologies applied for the assesment of the arm’s lenth prices/profit margins.

Our team will assist you in developing a comprehensive defence strategy and accompany your organisation’s representatives in meetings with the tax authorities.

Operating model development

We assist you in designing and implemending your Group’s operating model, developing an appropriate TP policy for splitting the profit between the Group’s entities and analysing the tax implications for the Group.

Advance Pricing Agreements (APAs)

Our specialists may assist you in developing an appropriate strategy and preparing documentation for entering into an APA, holding meetings and filing an APA with the tax authorities.