Transfer pricing is an issue that requires a great deal of attention as early as at the planning stage of any transaction between related parties. The issue of transfer pricing is invariably cited as a priority for all tax inspections and fiscal audits and remains the source of the highest additional tax assessment. The regulations and economic situation are also constantly changing, which significantly affects the related party operations.
Our support in the transfer pricing area is tailored to the individual needs of our clients. We carefully determine the scope of documentation and reporting obligations, take into consideration the applicability of statutory exemptions for micro and small businesses, recharging or safe harbour for financial services and low-value-added services as well as transactions that are “invisible” in the books.
Comprehensive transfer pricing services provided by Taxpoint include:
- preparing the Local File for transactions between related parties and for the so-called tax haven transactions
- preparing transfer pricing analyses in the form of benchmarking studies for financial, commodity, service and licence transactions based on national and international databases
- preparing compliance analyses confirming the arm’s length nature of prices in situations when a benchmarking study cannot be prepared (e.g. in case of reorganisation / restructuring processes)
- support in fulfilment of reporting obligations: reporting of transfer pricing information using the TPR form
- preparing or verifying the Master File
- advice and assistance in preparing the necessary documentation and operating under the Advance Pricing Agreements (APA)
- assistance with Country by Country (CbC) reporting
- support at every stage of tax inspection and proceedings
- developing system solutions and procedures in the transfer pricing area for the company (including e.g. a system for updating transfer pricing documentation, collection of source documentation confirming the performance of services in the case of intangible services)
- preparing analyses concerning the impact of objective factors on the result of a related party transaction (the defense file)
- day-to-day advisory services related to intragroup transactions, including analysis of risks, agreements concluded and transfer pricing adjustments made
- conducting tailor-made transfer pricing training sessions and workshops, etc.
