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Transfer pricing services
Market research consistently shows that for international business, transfer pricing continues to be the most significant international tax issue. Tax audits are becoming more focused in most countries, with an increasing number of specialists at the heart of the fiscal authorities. The exchange of information between different countries is becoming much more prevalent, leading to greater clarity over cross border tax takes.
The issue is not just confined to large multinationals. Medium sized and family businesses are also affected where their trading operations take them overseas. It is often in this area that there are easy pickings for tax inspectors descending on businesses which previously treated transfer pricing as a low priority.
Our transfer pricing team meet and work together frequently to a common standard, so you can be confident of consistency and good communication, key areas in the arena of International Taxation.
Our services consist (among other things) of:
- Drafting contracts between related entities and preparing transaction documentation with related entities, in accordance with art. 9a of the Act on corporate income tax;
- The review of settlements in transactions with related entities and the assessment of related fiscal risks;
- Assistance in the estimation of transactions between related entities - indicating the market price level, the margin and consulting in the selection of the best method of completing transaction settlements, including transactions concerning intangible assets;
- Assistance in the creation of documentation justifying the protection of costs related to services for related entities as fiscal costs;
- Fiscal and judiciary proceedings;
- Assistance and participation in fiscal audit/fiscal proceedings - including technical assistance, support in the preparation of explanatory statements and documents required for fiscal control, participation in negotiations with representatives of the tax authorities and in hearings of the company's representatives;
- Acting as proxy in the audit/proceedings;
- Appeals from the decisions of the general tax authorities and conducting cases before fiscal chambers;
- Preparing complaints on the decisions of the fiscal authorities to province administration courts and representation during the entire proceedings at the administration courts, including the Superior Court of Administration;
- Assistance in the preparation of corrections to tax settlements resulting from fiscal audits;
- Assistance in obtaining binding interpretation of tax regulations.
Related Publication
Transfer Pricing
11 November 2009
Transfer Pricing is the price at which goods and services are sold between associated enterprises. As the majority of the international trade takes place between allied enterprises, the Transfer Pricing range is enormous.
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